AO Not Obligated to Refer to TPO for Arm's Length Price After Section 92BA(i) Omission by Finance Act 2017.

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....Revision u/s 263 - AO ought to have made mandatory reference to the “TPO” for determining arm’s length price - Since the Finance Act, 2017 omitted sec. 92BA(i) from retrospective effect, the Assessing Officer’s inaction in not making reference to the TPO does not render the assessment erroneous causing prejudice to interest of the Revenue.- AT....