https://www.taxtmi.com/caselaws?id=446815 The ITAT Kolkata allowed the assessee's cross objection and deleted TP adjustments made by the AO regarding SDTs with AEs. The tribunal held that since clause (i) of section 92BA was omitted from the statute, it should be construed as never having existed. Consequently, no ALP determination was required for transactions with specified persons under section 40A(2)(b) of domestic transactions, making the reference to the TPO unnecessary. The decision relied on the Karnataka HC ruling in Texport Overseas Pvt. Ltd. en-us Wed, 29 Nov 2023 00:00:00 +0530 Tue, 12 Dec 2023 12:59:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446815 The ITAT Kolkata allowed the assessee's cross objection and deleted TP adjustments made by the AO regarding SDTs with AEs. The tribunal held that since clause (i) of section 92BA was omitted from the statute, it should be construed as never having existed. Consequently, no ALP determination was required for transactions with specified persons under section 40A(2)(b) of domestic transactions, making the reference to the TPO unnecessary. The decision relied on the Karnataka HC ruling in Texport Overseas Pvt. Ltd. Case-Laws Income Tax Wed, 29 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446815