In the result, appeal of the Assessee is Partly Allowed
Bench: Shri S.S.Godara & Dr. Dipak P. Ripoteआयकर अपील सं. / Ita No.134/Nag/2019 िनधा"रण वष" / Assessment Year : 2014-15 Sunil Narayndas Khatod, The Commissioner Of Nagpuri Gin Compound, Vs Income Tax-1, Behind Old Cotton Market, Nagpur. Nagpur – 444001. Pan: Adepk3087C Appellant/ Assessee Respondent/Revenue Assessee By Shri Rajesh V.Loya – Ca Revenue By Shri Kailash G. Kanojiya – Sr.Dr Date Of Hearing 21/09/2023 Date Of Pronouncement 21/11/2023
7. Ld.Pr.CIT has invoked jurisdiction u/s 263 on only one ground that the AO had not referred the case to the Transfer Pricing Officer for deciding the Arm’s length Price of “Specified 6 Sunil Narayandas Khatod [A] Domestic Transactions”. The Section 92BA was amended by Finance Act, 2017, the pre-amended section 92BA as on 2014 is reproduced here