Law empowers Transfer Pricing Officer to determine the arm’s length price of only ‘referred’ international transactions

Law empowers Transfer Pricing Officer to determine the arm’s length price of only ‘referred’ international transactions. Non-referred international transactions fall outside the TPO’s jurisdiction The Delhi Bench of the Income-tax Appellate Tribunal (the Tribunal) in the case  of M/s. Amadeus India Pvt Ltd Vs. ACIT, Range-I, New Delhi (ITA No. 5203/Del/2010) held that the role of Transfer Pricing Officer (TPO) is limited to the determination of arm’s length price in relation to the international transaction(s) referred to him by the Assessing Officer (AO). The TPO, suo motto, cannot...