S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Computation of Arm’s Length Price-Appeal to Appellate tribunal-Issues of inclusion and exclusion of comparables for determination of arms length price-Contentions regarding dissimilarities in product, function and on-site and off-shore revenues earned not considered and adjudicated by the tribunals-Matter remanded back to Tribunal.[S.92CA(3), 260A]