Held that the issue of disallowance of interest expenditure is subject of matter appeal before CIT(A). As regards transfer pricing Section 92BA(i) is omitted. w.e.f. 1st April, 2017, no ALP is required to be determined in respect of a domestic transaction. No reference was required to the TPO. Revision is bad in law. (AY. 2014-15)
IMC Ltd v. PCIT (2023) 226 TTJ 180 (Kol)(Trib)
S. 263 : Commissioner-Revision of orders prejudicial to revenue-Merger-Interest free funds-Issue is subject matter of appeal before CIT(A)-Revision is bad in law-Transfer pricing-Section 92BA(i) is omitted.w.e.f. I st April, 2017 No ALP is required to be determined in respect of a domestic transaction-No reference was required to the TPO-Revision is bad in law. [ S.14A, 40A(2), 92BA, 92C, R.8D]