https://www.taxtmi.com/caselaws?id=761191 The Karnataka HC upheld the tribunal's decision to delete additions made under Section 92BA(i), ruling that since this provision was omitted by Finance Act 2017 with effect from July 1, 2017, it is deemed never to have existed. Consequently, the Assessing Officer's decision and TPO reference under Section 92CA were invalid. The court further held that transfer pricing adjustments under Chapter X are restricted to international transactions between Associated Enterprises only, not transactions with independent third parties, as there is no tax avoidance concern with unrelated parties. The adjustment proposed by Revenue would improperly increase profits from non-AE transactions, exceeding Chapter X's scope. Decision favored the assessee. en-us Mon, 14 Oct 2024 00:00:00 +0530 Tue, 05 Nov 2024 09:52:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=761191 The Karnataka HC upheld the tribunal's decision to delete additions made under Section 92BA(i), ruling that since this provision was omitted by Finance Act 2017 with effect from July 1, 2017, it is deemed never to have existed. Consequently, the Assessing Officer's decision and TPO reference under Section 92CA were invalid. The court further held that transfer pricing adjustments under Chapter X are restricted to international transactions between Associated Enterprises only, not transactions with independent third parties, as there is no tax avoidance concern with unrelated parties. The adjustment proposed by Revenue would improperly increase profits from non-AE transactions, exceeding Chapter X's scope. Decision favored the assessee. Case-Laws Income Tax Mon, 14 Oct 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=761191