In Sony India (P.) Ltd., the Delhi High Court considered the constitutional validity of an instruction issued under Sec. 119 of the Income Tax Act. The taxpayer challenged as being arbitrary, unreasonable and ultra vires of the Act, the requirement that reference be made to the transfer pricing officer to determine the arm's length price where the aggregate value of cross-border transactions exceeds INR 50 million. This article analyses the relevant Income Tax Act provisions and the issues considered in the case.