A.O. not to to demonstrate tax avoidance before invocation of TP provisions

IN THE ITAT AHMEDABAD BENCH ‘D’ Atul Ltd. Versus Assistant Commissioner of Income-tax, Range-1 IT Appeal No. 3118 (Ahd.) of 2010 [Assessment Year 2006-07] October 29, 2012 ORDER Mukul Kr. Shrawat, Judicial Member  This is an appeal filed by the Assessee on Form No. 36B i.e ‘Memorandum of Appeal’ as prescribed u/s 253(1)(d) being a direct appeal emanating from the Assessment Order passed u/s 143(3) r.w.s.144C dated 22.10.2010. However, the chronology of the connected orders passed by the Revenue Authorities is as follows:- 1.  T.P.O. order U/s 92 CA(3...