A. High Court 1. Obulapuram Mining Company Pvt Ltd [TS-1262-HC-2019(KAR)-TP] Reference to the TPO to determine the ALP u/s 92CA(1) in terms of the CBDT Instruction No. 3/2003 is mandatory in nature and thus an assessment order passed without making any reference to the TPO, for determining the ALP, is erroneous, and liable for revisionary proceedings u/s 263 Facts The assessee, a domestic company engaged in the business of mining and export of iron ore, filed its return of income for AY 2008-09. During the year under consideration, the assessee had entered into international transactions with its AE i.e. M/s GLA Trading International PTE Ltd. The case of the assessee was selected for scrutiny assessment and the assessment was completed u/s 143(3) read with Section 153A of the Act, without making any reference to the TPO to determine the ALP of the said international tr.......