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Transfer Pricing Adjustments Invalid for 2016-17 Due to Omission of Section 92BA(i) from Income Tax Act.
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....TP adjustment - specified domestic transactions (SDT) - The ITAT held that since the provision (Section 92BA(i)) was omitted without a saving clause effective from 01/04/2017, any reference for TP adjustment to SDT under this clause was invalid. Therefore, for A.Y. 2016-17, no TP adjustment could be made under SDT, and the grounds of the assessee were allowed.....