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TPO can't determine ALP of specified domestic transactions not referred to him by AO: Bombay HC

March 26, 2019[2019] 103 388 (Bombay)

IT/ILT : In relation to a specified domestic transaction, TPO can under take transfer pricing study only in relation to those transactions which are referred to him under sub-section (1) of section 92C . Sub-section (2A) and (2B) of section 92C are confined to international transactions and with aid of any interpretive process, said provision cannot be applied to empower TPO to examine any specified domestic transaction not referred to him by Assessing Officer under sub-section (1). Thus, TPO cannot assume jurisdiction to determine arm's length price of a specified domestic transaction not reported to him

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