TPO could not assume jurisdiction to determine ALP of a SDT not reported to him

Times Global Broadcasting Company Ltd Vs Union of India & Ors. (Bombay High Court) It is indisputable that by virtue of sub-sections (2A) and (2B) of Section 92CA, in case of an international transaction, the TPO would have an authority to examine any international transaction which comes to his notice during the proceedings, whether a reference in this respect was made by the Assessing Officer or not and whether the assessee had reported such transaction under Section 92E of the Act or not. However, in view of specific non-inclusion of the specified domestic transaction under the said sub...