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Karnataka HC ruled that omission of Section 92BA(i) invalidates its application to domestic transactions, limiting transfer pricing adjustments to international dealings.
Thereafter an order u/s. 73(9) of the KGST Act was passed vide order dated 27.03.2024 whereunder the tax demand together with interest and penalty was made against the petitioner.
Supreme Court held that the reduction in share capital of the subsidiary company and subsequent proportionate reduction in the shareholding of the assessee would be squarely covered within the meaning of transfer under Section 2(47) of the Income Tax Act.
ITAT Allahabad held that order passed by PCIT without considering the contentions of the assessee is against the principles of natural justice and accordingly is liable to be set aside. Accordingly, appeal of the assessee allowed.
