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Showing contexts for: autodesk in Autodesk India Private Limited, ... vs Dcit, Bangalore on 8 June, 2018Matching Fragments
Without prejudice to the above, the order issued by the AO is bad in law insofar as the fact that the AO did not issue to Autodesk India Private Limited (`the Appellant or 'the Company'), a show cause notice, as per proviso to section 92C(3) of the Income-tax Act, 1961 ['the Act'].
b) The AO has erred in law in making a reference to the Deputy Commissioner of Income-Tax, (Transfer Pricing) - IV [`TPO'], inter alia, since he has not recorded an opinion that any of the conditions in section 92C(3) of the Act, were satisfied in the instant case.