https://www.taxtmi.com/caselaws?id=459334 A challenge to a transfer pricing notice and the Assessing Officer's reference turned on whether the transaction, on its face, was not an international transaction and whether the Assessing Officer had formed the requisite opinion on material before making the reference. The Court noted the Revenue's position that the statutory scheme permits a reference where the Assessing Officer considers it necessary or expedient, and that the material could indicate an associated enterprise relationship and an international transaction. It declined to interfere in writ jurisdiction under Article 226 and left the notice and reference undisturbed. en-us Thu, 22 May 2014 00:00:00 +0530 Mon, 09 Dec 2024 19:05:35 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=459334 A challenge to a transfer pricing notice and the Assessing Officer's reference turned on whether the transaction, on its face, was not an international transaction and whether the Assessing Officer had formed the requisite opinion on material before making the reference. The Court noted the Revenue's position that the statutory scheme permits a reference where the Assessing Officer considers it necessary or expedient, and that the material could indicate an associated enterprise relationship and an international transaction. It declined to interfere in writ jurisdiction under Article 226 and left the notice and reference undisturbed. Case-Laws Income Tax Thu, 22 May 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=459334