No specific provisions for giving any opportunity to the assessee before reference to TPO

IN THE ITAT AMRITSAR BENCH I.J. Tools & Castings (P.) Ltd. versus Assistant Commissioner of Income-tax, Range-II, Jalandhar IT APPEAL NOS. 63 & 84 (ASR.) OF 2010 & 65 (ASR.) OF 2012 [ASSESSMENT YEAR 2005-06] JULY 26, 2012 ORDER 1. These cross appeals of the assessee and the Revenue arise from the order of the Ld. CIT(A), Jalandhar, dated 25.11.2009 for the assessment year 2005-06. The assessee has also filed appeal against the order of the CIT(A), Jalandhar, dated 19.01.2012 with regard to penalty under section 271(1)(c) of the Act for the assessment year 2005-06. ...