AO Failed to Issue Show Cause Notice for Transfer Pricing Adjustment, Violating Section 92CA(1) of Income Tax Act.

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....TP adjustment - effect of non issue of SCN by AO - Though the AO records reasons and even gets those reasons approved by CIT and clearly mentions the reasons for reference in the referral letter but fails to show cause the same to assessee. The said act of Assessing Officer is in contradiction to the provisions of section 92CA(1)....