Revisionary order violating CBDT instruction no. 3/2016 is unsustainable

Zydus Healthcare Limited Vs PCIT (ITAT Kolkata) ITAT Kolkata held that CBDT instruction no. 3/2016 exempt referring the specified domestic transactions with AE to TPO. Thus, revisionary order directing AO to pass fresh assessment order after making reference to TPO is unsustainable. Facts- On scrutiny of the assessment record, Commissioner formed an opinion that the assessee had entered into specified domestic transactions with its Associated Enterprises, namely Cadilla Healthcare Limited. He referred to such a transaction and observed that the Assessing Officer should have referred to the TPO...