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 transactio

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