AO's Transfer Pricing Adjustments Invalid if Over Rs. 5 Crores Without TPO Referral, Breaching CBDT Rules.

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....TPA - Jurisdiction of the AO in making the assessment without referring the matter to the Transfer Pricing Officer where the value of international transactions exceeded ₹ 5 crores - Transfer Pricing adjustments made by the AO in contradiction to the mandatory instructions of the CBDT is bad in law.- AT....