Allowing the petition as per  CBDT Instruction No 3 of 2016 dt.10 3-2016 satisfaction should have been recorded that there ought to be an income or potential of an income arising and/or being affected on determination of ALP of an international transaction or specified domestic transaction and in absence of such satisfaction being recorded in order disposing of objections, reference to TPO would be without jurisdiction. (AY 2017-18)