Section 92C of the Income Tax Act, 1961 — Transfer Pricing — It was the specific claim of the AO that the entire activities of the assessee squarely fell within his power and jurisdiction for determination of the taxable income by himself without referring to the TPO, therefore, this factual dispute had to be settled first for which purpose only the DRP was constituted. Assessee had alternate remedy against draft assessment order — EOS GmBH India Branch vs. Deputy Commissioner of income tax [2020] 420 ITR 119 (Madras)