The Principal Commissioner Of Income ... vs M/S S.G. Asia Holdings (India) Pvt. Ltd.

The Supreme Court upheld the Tribunal's decision that the transfer pricing adjustments made by the Assessing Officer under Section 92 of the Income Tax Act, 1961 were invalid due to non-compliance with mandatory instructions issued by the CBDT under Instruction No.3/2003. The Court emphasized that the Assessing Officer's failure to refer the matter to the Transfer Pricing Officer constituted a breach of statutory requirements, rendering the adjustments bad in law. Consequently, the appeal was dismissed, affirming the Tribunal's ruling.