TPO cannot suo-motu assume jurisdiction to determine ALP price of SDT not referred to him

Times Global Broadcasting Company Ltd vs. Union of India & Ors. (Bombay High Court) Whether the Transfer Pricing Officer can examine any specified domestic transaction, even if the same is not specifically referred to him by the Assessing Officer? Hon’ble Bombay High Court (HC) held that the transfer pricing officer (TPO) cannot suo-motu assume jurisdiction to determine the arm’s length price (ALP) of specified domestic transactions (SDT) not referred to him. Facts of the case: – Times Global Broadcasting Company Ltd (the petitioner), is a wholly owned subsidiary of Benett, Colem...