In the result, appeal of the assessee is allowed

Bench: Shri R.S. Syal, Hon. Vice- & Shri Partha Sarathi Chaudhury, Hon.M/S. Jyoti Paper Udyog Ltd., Vs Acit, Circle-1, Plot No.B67, Nice, Midc Nashik. Satpur, Nashik – 422 007 Pan: Aaacj 7288 E Appellant Respondent Assessee By : Shri Sanket M. Joshi, Ca Revenue By : Shri Ramnath P Murkunde, Dr Date Of Hearing : 06/09/2023 Date Of Pronouncement : 20/09/2023 O R D E R Per Partha Sarathi Chaudhury, Jm: This Appeal Preferred By The Assessee Emanates From The Order Of National Faceless Appeal Centre [Nfac], Delhi, Dated 28.04.2023 For A.Y.2013-14 As Per The Grounds Of Appeal On Record.

disallowance u/sec. 40A(2) would not be attracted. Accordingly, considering the intention of Legislature behind bringing the specified domestic transactions within the ambit of Transfer Pricing Regulations, in my opinion, the provisions of section 92C, 92D and 92E would not have application in the case of the assessee company.” The assessee, on a bonafide belief, has referred