| COURT: | Gujarat High Court |
| CORAM: | B. N. Karia J, M. R. Shah J |
| SECTION(S): | 92, 92C |
| GENRE: | Transfer Pricing |
| CATCH WORDS: | Reference, Transfer Pricing |
| COUNSEL: | R. K. Patel |
| DATE: | November 16, 2016 (Date of pronouncement) |
| DATE: | December 8, 2016 (Date of publication) |
| AY: | - |
| FILE: | Click here to view full post with file download link |
| CITATION: | |
| Transfer Pricing: As per CBDT's Instruction No.3/2016 dated 10.03.2016, the AO is required to give an opportunity to the assessee to show cause why the reference should not be made to the TPO and thereafter pass a speaking order while making a reference to the TPO. The failure to do so renders the reference void | |
No speaking order has been passed by the Assessing Officer while making a reference to the TPO, which is a requirement as per the Instruction No.3/2016 dated 10th March, 2016, issued by the CBDT. Before making a reference to the TPO, the assessee is required to be given an opportunity to show cause why the reference may not be made to the TPO and thereafter a speaking order is required to be passed by the Assessing Officer while making a reference to the TPO
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