AKIL KURESHI, J.

1. The petitioner has challenged an order dated 15.10.2018 as at Annexure “M” to the petition passed by the Transfer Pricing Officer (“TPO” for short) under Section 92CA(3) of the Income Tax Act, 1961 (“the Act” for short).

2. Brief facts are as under:-

2.1 Petitioner - Times Global Broadcasting Company Ltd is a company registered under the Companies Act, 1956 and his a wholly owned subsidiary of Benett, Coleman and Company Ltd (hereinafter referred to as “BCCL”). The petitioner is engaged in the business of distribution of television channels for the Times Group entities. It also provides support services to Times Group entities in the area of finance, legal, human resources, commercial, administration and technical and broadcasting. With effect from 1.4.2014, the petitioner demerged one of its business undertakings into BCCL. The scheme of demerger was approved by the High Court at Bombay by an order dated 16.1.2015. Consequently, the business pertaining to “Times Now” television channel of the petitioner got vested in BCCL. All assets and liabilitie