Mere Form No. 3CEB filing cannot make assessee liable for Section 92BA investigation

Ashish Subodhchandra Shah (HUF) Vs PCIT (ITAT Ahmedabad)

The issue under consideration  is whether all the domestic transactions with an Associate Enterprise (AE) would constitute “Specific Domestic Transactions” for the purpose of Section 92BA of the Act?

In the present case, the Principal Commissioner of Income Tax invoked his revisional jurisdiction under section 263 of the Income Tax Act, 1961 on the ground that despite the domestic transactions undertaken by the

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