Shanti Prime Publication Pvt. Ltd.
Sec. 92CA of Income Tax Act, 1961 – Transfer Pricing – Revenue filed SLP against the order of High Court of disposing of the writ petitions of the petitioners observing that “the question of whether or not a reference should be made to the TPO, for the three AYs in question, will now be determined by the AO afresh after giving the Petitioner an opportunity of being heard in respect of each of the AYs within the next 15 days. At least one week's advance notice be given to the Petitioner of the exact date of hearing before the AO”. The question of law were involved in the writ petitions regarding the procedure adopted by the AO while referring to the TPO under Section 92 CA of the Act, 1961, the question of determination of the ALP of the international transaction entered into by the Petitioner Assessee with its Associated Enterprise. Supreme Court granted Leave – ADDI. CIT
Vs. INDORAMA SYNTHETICS (INDIA)(P.) LTD. [2020] 269 TAXMAN 578 (SC)