Held that Section 92BA(i) has been omitted w.e.f.Ist April 2017, without any saving clause. It is deemed that the said clause (i) was never in the statute, therefore reference made to the TPO under section 92CA qua transactions falling under Clause (i) of Section 92BA is invalid. Accordingly the order passed by TPO and Assessing Officer is bad in law. (AY. 2014-15)
Worship Infraprojects (P) Ltd v. Dy.CIT(2023) 226 TTJ 649 (Jaipur)(Trib)
S. 92BA : Transfer pricing-Specified domestic transaction-Arm’s length price-Avoidance of tax-Omitted with effect from Ist April 2017-No saving clause-Order is bad in law.