Held that since section 92BA(i) was unconditionally omitted without a saving clause in favour of pending proceedings and it does not say that pending proceedings under clause (i) of section 92BA would continue in future even after its omission on 1-4-2017, Commissioner ought not to have proceeded under section 263 of the Act. (AY. 2016-17)
Automark Industries (India) (P.) Ltd. v. PCIT (2022) 194 ITD 172 (Nagpur)(Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Specific domestic transaction-Order passed without referring domestic transaction to TPO-Section 92BA(i) was unconditionally omitted without a saving clause-Revision is not valid. [S. 92BA(i)]