Court held that the instruction No. 3 of 2003 ([2003] 261 ITR (St.) 51) issued by the Central Board of Direct Taxes states that wherever the aggregate value of international transaction exceeds Rs. 5 crores (amended to Rs. 15 crores), the case must be picked up for scrutiny under section 92CA of the Income-tax Act, 1961 and sent to the Transfer Pricing Officer for determination of the arm’s length price. In view of the unambiguous language employed in S. G. Asia Holdings’ case by the Supreme Court Instruction No. 3 of 2003 issued by the Central Board of Direct Taxes is mandatory. (AY. 2008-09)