ITAT refer TP adjustment for Notional Interest to Special Bench

Ampacet Cyprus Limited Vs DCIT (ITAT Mumbai) The issue under consideration is whether transfer pricing adjustment as notional interest and charging it to tax, disregarding the provisions of Article 11 of India Cyprus DTAA is justified in law? ITAT states that, in the event of a doubt about the correctness of the earlier decision or, extending that logic a little further, correctness of the path the earlier decisions have traversed to come to a conclusion, it is open to the bench to make a reference to for constituting a larger bench for considering the same. In the case of Union of India v. Pa...