information or documents referred to in sub-section (3) of section 92D and after considering such evidence as the Transfer Pricing Officer may require ... functions of an Assessing Officer specified in sections 92C and 92D in respect of any person or class of persons
Section 92D in The Income Tax Act, 1961
92D. Maintenance and keeping of information and document by persons entering into an international transaction.
(1) Every
where the assessee had maintained information and documents as prescribed under section 92D, declared the international transaction under Chapter X, and, disclosed all the material
domestic transaction.
- For the purposes of this section and sections 92, 92C, 92D and 92E, "specified domestic transaction" in case of an assessee means
accordance with the provisions contained in Sub-section (1) of Section 92D , and the rules made in this behalf or the information or data used ... furnish by a notice issued under Sub-section (3) of section 92D , the assessing officer may proceed to determine, after giving an opportunity of being
domestic transaction. - For the purposes of this Section and sections 92, 92C, 92D and 92E, "specified domestic transaction" in case of an assessee means
except the second proviso to sub-section (2)], 92CA, 92CB, 92D, 92E and 92F shall apply accordingly. (3) Notwithstanding anything to the contrary contained
Finance Act, 2012
38. Amendment of Chapter X.
- In sections 92C, 92D and section 92E of Chapter X of the Income
purposes of this section and sections 92 ,
92B , 92C , 92D , 92E and 92F , associated enterprise, in
relation to another enterprise, means an enterprise
(a) which ... purposes of this section and sections 92 ,
92C , 92D and 92E , "international transaction" means a
transaction between two or more associated enterprises,
either
holding that there was reasonable cause for non-compliance
of sec.92D read with Rule 10D(1) without specifying the cause of such
non-compliance ... Tulsibhai
Dholakia
Pintu Tulsibhai Dholakia
Dholakia
Ankit Bharatbhai Patel
Notices under Sec. 92D(3) r.w Rule 10D were issued