Held that by virtue of deletion by the Finance Act 2017, with effect from April 1, 2017 of clause (i) of section 92BA, the ambit of section 40A(2(b) is not available. Accordingly the upward adjustment made by the Transfer Pricing Officer in respect of the arm’s length price of the specified domestic transactions are deleted. (AY.2015-16)
Asiatic Colour Chem Ind. Ltd. v. Jt. CIT (2024)116 ITR 7 (SN)(Ahd)(Trib)
S. 92BA : Transfer pricing-Specified domestic transaction-Arm’s length price-Avoidance of tax-Excluded from definition with effect from 1-4-2017-Omission has retrospective effect-Addition is deleted. [S.40A(2)(b)]