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Vide Case Reference: [2022] 447 ITR 585 (All) the instructions issued by the board u/s 119 need to be implemented truly and effectively. If not then the doors to the court get opened up. 


Instruction No. 3 of 2003 admits to the role of the TPO limited to the determination of the arm’s length price in relation to the international transaction(s). 


Anything and everything that he experiments to do such as an attempt to change the nature or classification of a transaction different to that in the taxpayer’s books of accounts is beyond his reach and therefore can be a matter of challenge in writ Court. 

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