Gujrat HC decides at what stage it can be held that there had been an international transaction between taxpayer and its Associated Enterprises

Veer Gems v. ACIT (Gujarat High Court) – It is necessary that the taxpayer should have entered into an international transaction with an associated enterprise in order to make reference by the Assessing Officer (AO). However, there is no provision under Chapter-X, which requires the AO to hear the taxpayer, consider the objections and only thereafter make a reference to the Transfer Pricing Officer ( TPO). The AO has to form an opinion, i.e., consider it necessary or expedient to make a reference, on the basis of available material on record and such opinion would have ad-hoc finality f...