Power of TPO to determine ALP of international transaction not referred to him by A.O.

ITAT DELHI Nokia India (P.) Ltd. V/s. Additional Commissioner of Income-tax IT APPEAL NO. 4559 (DELHI) OF 2011 [ASSESSMENT YEAR 2007-08] MAY 18, 2012 ORDER K.D. Ranjan, Accountant Member This appeal by the assessee for Assessment Years 2007-08 arises out of the order of the Assessing Officer passed under sec. 143(3) read with section 144C of the Income-tax Act, 1961 (the Act). 2. During the course of hearing the assessee filed additional ground which reads as under:- “Without prejudice to our other grounds of appeal, the learned Transfer Pricing Officer (“TPO&#...