In an emerging thinking document published in January, the Competition Commission said its inquiry into the grocery industry would turn its attention to retailer competition in local areas.
It defined the local market as stores within a 10-15 minute drive of a consumer's house.
However, Tesco's submission says the Commission has “seriously underestimated” the local market, arguing it should include all supermarkets within a 30-minute drive.
"We have submitted a serious economic proposition,” Tesco's corporate affairs director Lucy Neville-Rolfe told the Sunday Telegraph.
“We hope that the evidence we have submitted will force the commission to review its definition."