Where TPO had not followed any method prescribed under the Act for determination of arm’s length price and Revenue did not controvert such finding, the Tribunal was justified in following the decision in CIT v. Kodak India (P.) Ltd. (2017] 79 taxmann.com 362 /[2016] 288 CTR 46 (Bom)(HC)   and holding that failure of TPO to follow a method prescribed by law did not entitle him to rectify the mistake in a second innings. Where the tax effect in Revenue’s appeal was below Rs. 2 crore and, in terms of the CBDT Circular dated 15-3-2024, tax effect was to be confined to the issues against which the appeal was intended, Revenue’s appeal was liable to be disposed of on the ground of low tax effect. (AY. 2011-12)