High Court Overturns ITAT Decision, Rules CBDT Instruction No.3 of 2003 Binding on Assessing Officer in Transfer Pricing Case.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....Revision u/s 263 - Whether Tribunal is right in holding that, CBDT Instruction No.3 dated 20.05.2003 is not binding on the AO and as such the AO himself determining the Transfer Pricing adjustment is justified and hence the order of assessment cannot be said to be erroneous - The impugned order passed by the ITAT is clearly unsustainable - HC....