https://www.taxtmi.com/caselaws?id=3400 The court upheld the validity of Instruction No. 3 of 2003 issued by the Central Board of Direct Taxes (CBDT) and dismissed the writ petition challenging its legality. It clarified the roles of the Assessing Officer (AO) and Transfer Pricing Officer (TPO) under the Income-tax Act, preserving the AO's discretion in determining the arm's length price (ALP) and emphasizing that the TPO's determination was not binding. The court highlighted the instruction's role as guidance to enhance efficiency, subject to periodic review by the CBDT. The petitioner's request to quash the assessment order was declined, with the court directing the petitioner to address additional grounds in the pending appeal before the Commissioner of Income-tax (Appeals). en-us Mon, 16 Oct 2006 00:00:00 +0530 Sun, 06 Feb 2011 05:37:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=3400 The court upheld the validity of Instruction No. 3 of 2003 issued by the Central Board of Direct Taxes (CBDT) and dismissed the writ petition challenging its legality. It clarified the roles of the Assessing Officer (AO) and Transfer Pricing Officer (TPO) under the Income-tax Act, preserving the AO's discretion in determining the arm's length price (ALP) and emphasizing that the TPO's determination was not binding. The court highlighted the instruction's role as guidance to enhance efficiency, subject to periodic review by the CBDT. The petitioner's request to quash the assessment order was declined, with the court directing the petitioner to address additional grounds in the pending appeal before the Commissioner of Income-tax (Appeals). Case-Laws Income Tax Mon, 16 Oct 2006 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=3400