https://www.taxtmi.com/highlights?id=105889 Fresh transfer-pricing references initiated after the omission of section 92BA(i) cannot sustain adjustments to related-party subscription fees for earlier years where the payments fall solely within the omitted category and no surviving category is invoked. Omission of a Central Act provision may amount to repeal, with section 6 of the General Clauses Act preserving accrued obligations and permitting later proceedings unless a different legislative intention appears. Neither the absence of an express saving nor the initiation date alone is conclusive. This treatment does not extinguish all earlier obligations or reopen completed determinations. Without an independent determination under section 40A(2)(a), the adjustments cannot be sustained as disallowances under that provision. en-us Fri, 06 Nov 2026 10:55:08 +0530 Fri, 06 Nov 2026 10:55:07 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=105889 Fresh transfer-pricing references initiated after the omission of section 92BA(i) cannot sustain adjustments to related-party subscription fees for earlier years where the payments fall solely within the omitted category and no surviving category is invoked. Omission of a Central Act provision may amount to repeal, with section 6 of the General Clauses Act preserving accrued obligations and permitting later proceedings unless a different legislative intention appears. Neither the absence of an express saving nor the initiation date alone is conclusive. This treatment does not extinguish all earlier obligations or reopen completed determinations. Without an independent determination under section 40A(2)(a), the adjustments cannot be sustained as disallowances under that provision. Highlights Income Tax Fri, 06 Nov 2026 10:55:08 +0530 https://www.taxtmi.com/highlights?id=105889