AO bound to refer to TPO for computation of ALP of international transactions

Bank of India Vs JCIT (ITAT Mumbai) Conclusion: PCIT rightly directed Bank of India’s case to TPO for determination of arm’s length price (ALP) in relation to international transactions and specified domestic transactions under revision proceedings as it was binding on AO as per the CBDT Circular in force at that point of time under Section 92CA  to refer this issue to the TPO even though he might be of the opinion that the international transactions carried by assessee were within arm’s length price. Held:  During revision proceedings, PCIT came across that assessee had made large int...