2014 (8) TMI 1016

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..... was made by the Assessing Authority to the Transfer Pricing Authority, there was no return pending for consideration by him and therefore, the very reference was bad. Even otherwise, the said Transfer Pricing Authority did not find fault with the adjudication of determining arm s length price by the Assessing Authority. In those circumstances, the Commissioner committed an error in exercising his .....

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..... r Section 143(1) of the Income Tax Act. The assessee received notices dated 1st of April, 2004 under Section 148 of the Act and 12th April 2004 under Section 92CA of the Act from the Transfer Pricing Officer seeking details about the international transactions entered into by the assessee with the group companies on a reference made by the Assessing Authority. At the time of issue of notice under .....

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..... d set aside the order of the Assessing Authority on the ground that it is erroneous and prejudicial to the interest of the revenue. It is against that order the assessee preferred an appeal to the Tribunal. 3. The Tribunal has held that when two views are possible and when the Transfer Pricing Authority has accepted valuation by the Assessing Authority determining the arm s length price, the Co .....

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