https://www.taxtmi.com/caselaws?id=780044 ITAT PUNE - AT upheld CIT(A)'s deletion of the TP adjustment and addition made by AO where TPO had applied internal CUP as MAM and AO rejected CPM, finding clause (i) of s.92BA omitted by Finance Act, 2017 w.e.f. 01.04.2017 operated with no saving clause and is to be treated as never having existed; consequently there was no infirmity in deleting the addition and the Revenue's grounds were dismissed. Penalty under s.271AA for non-maintenance of records relating to ALP of specified domestic transactions was also deleted. en-us Fri, 26 Sep 2025 00:00:00 +0530 Fri, 17 Oct 2025 08:08:42 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=780044 ITAT PUNE - AT upheld CIT(A)'s deletion of the TP adjustment and addition made by AO where TPO had applied internal CUP as MAM and AO rejected CPM, finding clause (i) of s.92BA omitted by Finance Act, 2017 w.e.f. 01.04.2017 operated with no saving clause and is to be treated as never having existed; consequently there was no infirmity in deleting the addition and the Revenue's grounds were dismissed. Penalty under s.271AA for non-maintenance of records relating to ALP of specified domestic transactions was also deleted. Case-Laws Income Tax Fri, 26 Sep 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=780044