SC: Reserves judgment on validity of HC-order invalidating TP-adjustment absent TPO-reference

Aug 06,2019

SC admits Revenue’s SLP and reserves judgment on validity of HC-order invalidating TP-adjustment absent TPO reference (where value of international transaction exceeded Rs. 5cr) for AY 2005-06; Noting that AO’s action of not making a reference to the TPO was in contravention to CBDT Instruction 3/2003 and finding no acceptable reason for refusing to abide by the condition of mandatory reference to TPO  as per CBDT circular wh...


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