Section 92 & 92CA of the Income Tax Act, 1961 — Transfer Pricing — Computation of arms length price—AO made Transfer Pricing adjustment without making reference to TPO under section 92CA being contrary to the mandatory instructions issued by CBDT vide Instruction No 3 of 2003 dt. 20th May, 2003 was bad in law. matter ought to have been restored to the AO so that appropriate reference could be made to the TPO — Principal Commissioner of income tax vs. SG Asia Holdings India P. Ltd. [2019] 310 CTR (SC) 1