Transfer Pricing Dispute Resolved: ITAT Nullifies Statutory Amendment and Blocks Adjustments for Domestic Specified Transactions

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....ITAT adjudicated a transfer pricing dispute regarding the omission of section 92BA clause (i) by Finance Act, 2017, effective 01.04.2017. The tribunal determined that since the reference to Transfer Pricing Officer (TPO) was made post-04.2017, the omitted clause cannot be invoked. Consistent with prior ITAT bench rulings, the tribunal held that the deleted statutory provision should be considered as never having been part of the statute. Consequently, no transfer pricing adjustments can be made for domestic specified transactions. The decision was rendered in favor of the assessee, effectively invalidating the transfer pricing reference as legally unsustainable under the amended statutory framework.....