JUDGMENT :

K.R. SHRIRAM, J.

1. The questions of law proposed are as under:

SUBSTANTIAL QUESTION OF LAW

1. Whether on the facts and in circumstances of the case, the Hon’ble Tribunal was correct in holding that the reasons recorded by the assessing officer in the present case does not meet with the requirement of Section 147 of the Income Tax Act 1961?

2. Whether on the facts and circumstances of the case, the Hon’ble Income Tax Appellate Tribunal was correct in holding that the Assessing Officer has no jurisdiction to issue notice under Section 148 of the Act?

3. Whether on the facts and circumstances of the case, the Hon’ble Income Tax Appellate Tribunal was justified in the quashing the order passed under Section 143(3) r/w Section 147 and 144C of the Act?

4. Whether on the facts and circumstances of the case, the Hon’ble Income Tax Appellate Tribunal was correct in holding that order of the Transfer Pricing Officer passed on 22/10/2010 is null & void ab initio as reference to the Transfer Pricing Officer to determine Arms Length Price cannot be initiated in the case of assessee, in the absence of any proceeding pending before Assessing Officer and reference for determination of Arms Le