TPO cannot go beyond ITAT instruction in matter remanded to him

Facts :- Narrow controversy which requires resolution in this proceeding, is whether the show cause notice impugned by the assessee could have been issued, in the manner done by the Revenue. The assessee’s threshold argument is that the ITAT’s remit was limited to complying with its directions and did not under any circumstances extend to questioning the basis for the TP exercise. The Revenue relies on Rule 10-B of the Income Tax Rules to say that the appropriateness of the com parables adopted by the assessee had not been gone into for the previous and that it is not bound by assumption b...