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“opportunity of being heard”

Natural JusticeAudi Alteram PartemAudi Alteram Partem22,508 judgments

The decision most relied on for opportunity of being heard is CIT v. Multiplan India Ltd. (38 ITD 320), cited in 2,267 judgments on BharatTax.

Leading authorities on opportunity of being heard

CIT v. Multiplan India Ltd.
38 ITD 320 · 1991 · ITAT
2,267
citing judgments

An appeal before the Income Tax Appellate Tribunal can be dismissed for non-prosecution or treated as unadmitted when the appellant fails to appear, cooperate, or show diligence, in accordance with Rule 19(2) of the Income-tax (Appellate Tribunal) Rules. The law aids the vigilant, not those who sleep on their rights.

CIT v. B.N. Bhattacharya & Another
118 ITR 461 · 1997 · Supreme Court
1,656
citing judgments

Appealing a tax assessment requires more than just filing the appeal; it involves actively pursuing it. The assessee must effectively engage with the appellate process.

Rashmikant Kundalia v. Union of India
54 Taxmann.com 200 · 2015 · High Court
702
citing judgments

Section 234E, levying late fees for delayed filing of TDS statements under section 200(3), is constitutionally valid and constitutes a compensatory fee, not a punitive penalty. Before treating any person as an assessee-in-default, an opportunity of being heard must be provided.

Tin Box Company v. CIT
249 ITR 216 · 2001 · Supreme Court
624
citing judgments

When an issue is remitted to the Assessing Officer for fresh adjudication, the AO must conduct a de novo examination and provide the assessee a full opportunity of being heard. The assessee is bound to comply with the notices issued by the AO.

CIT v. Vikas Polymers
341 ITR 537 · 2012 · High Court
318
citing judgments

An assessment order is not erroneous and prejudicial under Section 263 merely because the Assessing Officer did not record an enquiry and its satisfactory answer in the assessment order, provided such an enquiry was conducted. For revision under Section 263, the Commissioner must also provide the assessee an opportunity of being heard and examine their explanation.

Commissioner of Income Tax Madras v. Chenniyappa Mudiliar
1 SCC 591 · 1985 · Reported
225
citing judgments

The appellate tribunal must render a proper decision on both facts and law, disposing of an appeal on its merits rather than dismissing it solely due to the appellant's absence. This obligation is derived from Section 33(4) of the Income Tax Act, 1922, and reflects principles of natural justice.

ITO v. M. Pirai Choodi
334 ITR 262 · 2011 · Supreme Court
211
citing judgments

If an assessee was denied an adequate opportunity of being heard, including the right to cross-examine a witness, the assessment should be set aside and restored for fresh adjudication after affording due opportunity, even if the assessee failed to appear at an appellate stage. The Tribunal, in the interest of justice, should ensure such matters are re-adjudicated.

Indian & Eastern Newspaper Society v. CIT
119 ITR 996 · 1979 · Supreme Court
205
citing judgments

An assessment cannot be reopened under Section 147/148 based on a mere change of opinion by the Assessing Officer on material already considered during the original assessment, clarifying the scope of 'escaped assessment'.

Judgments citing opportunity of being heard

Apostle Trading Consultants P.Ltd, New Delhi vs. DCIT, Circle-3(1), New Delhi

In the result, appeal filed by the Assessee stands allowed for statistical purpose

ITA 2484/DEL/2018[2014-15]Status: DisposedITAT Delhi27 Jun 2023AY 2014-15

Bench: Sh. Anil Chaturvedi, Hon’Blesh. N.K. Choudhry, Hon'Bleapostle Trading Consultants Private Vs. Dcit – Circle – 3(1) Limited New Delhi B-304, New Friends Colony New Delhi - 110065 Pan: Aahca2341Q

Section 250

case is remitted to the file of the Assessing Officer for decision afresh in the aforesaid terms, suffice to say by affording reasonable opportunity of being heard to the Assessee. Page No. 10 Apostle Trading Consultants Private Limited 12. In the result, appeal filed by the Assessee stands allowed

Vadasada Charitable Trust, Surat vs. Commissioner of Income Tax (Exemption), Ahmedabad

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 198/SRT/2023[2022-23]Status: DisposedITAT Surat27 Jun 2023AY 2022-23

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकर अपील सं./Ita No.198/Srt/2023 (Virtual Court Hearing) Vadasada Charitable Trust Commissioner Of Income Tax C/O 701 7Th Floor Meridian Towers, (Exemption), Ahmedabad, Aayakar Vs. Ring Road, Udhna Darwaja, Surat- Bhawan, Ashram Road, 395002 Ahmedabad-380009 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aadtv 6713 C (अपीलाथ" /Assessee ) (""थ"/Respondent)

For Appellant: Shri Kishorbhai R Gheewala, C.AFor Respondent: Shri Ashok B. Koli, CIT-DR

note that it is settled law that principles of natural justice and fair play require that the affected party is granted sufficient opportunity of being heard to contest his case. Therefore, without delving much deeper into the merits of the case, in the interest of justice, we restore the matter ... back to the file of Ld. CIT(Exemption) for de novo Vadasada Charitable Trust adjudication and pass a speaking order after affording sufficient opportunity of being heard to the assessee, who in turn, is also directed to contest his stand forthwith. Therefore, we deem it fit and proper

M/S Rudra Developers, Surat vs. Dy. Commissioner of Income Tax, Cir- 1(1)(1), Surat

In the result, the ground of appeal raised by the assessee is allowed for statistical purposes

ITA 132/SRT/2023[2013-14]Status: DisposedITAT Surat27 Jun 2023AY 2013-14

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(1)Section 143(3)Section 154Section 254(1)

subject, the ld. CIT(A),NFAC has passed order against the principle of natural justice, equality and fair by not providing reasonable opportunity of being heard despite the fact that assessee requested for adjournment. 2. On the facts and circumstances of the case as well as law on the subject

M/S Rudra Developers, Surat vs. Dy. Commissioner of Income Tax, Cir- 1(1)(1), Surat

In the result, the ground of appeal raised by the assessee is allowed for statistical purposes

ITA 131/SRT/2023[2013-14]Status: DisposedITAT Surat27 Jun 2023AY 2013-14

Bench: Shri Pawan Singh & Dr. Arjun Lal Saini

Section 143(1)Section 143(3)Section 154Section 254(1)

subject, the ld. CIT(A),NFAC has passed order against the principle of natural justice, equality and fair by not providing reasonable opportunity of being heard despite the fact that assessee requested for adjournment. 2. On the facts and circumstances of the case as well as law on the subject

Ram Charan Gupta, Jaipur vs. ITO WD 4(2), Jpr

In the result, appeal of the assessee is allowed

ITA 408/JPR/2022[2020-21]Status: DisposedITAT Jaipur27 Jun 2023AY 2020-21

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Sh. Manoj Kumar Gupta (CA)For Respondent: Smt Monisha Choudhary(Addl. CIT)
Section 10Section 143(1)

that there was enhancement in the income amounting by Rs.397100.00 and assessing total income at Rs 1188620.00 This was made without providing any opportunity of being heard as it appears that this addition was made by treating the employee as non-government employee although no specific reasons has been informed ... correct proposition as per principal of natural justice it becomes mandatory on the part of assessing officer to provide the opportunity of being heard however factually employer of the appellant is govt therefore he is entitle for deduction of Rs 697000.00. 4. Kindly stay the demand. As disallowance has been

Sarabuild Homes Private Limited, Jalwar vs. Income Tax Officer, Alwar

In the result, the appeal of the assesee is allowed for statistical purposes

ITA 316/JPR/2022[2012-2013]Status: DisposedITAT Jaipur27 Jun 2023AY 2012-2013

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Saurav Harsh (Adv.)For Respondent: Smt. Monisha Choudhary (Addl.CIT)
Section 143(3)Section 147Section 148Section 68

filing the appeal is allowed and restore the matter to the file of the ld. CIT(A) decide it afresh by providing reasonable opportunity of being heard to the assessee.The Ld. DR does not have any objection but prays to direct the assessee to represent his case before

Uttam Ghewarchand Shrishrimal, Mumbai vs. ITO 19(3)(5), Mumbai

In the result, the appeal is allowed for statistical purpose

ITA 716/MUM/2023[2011-12]Status: DisposedITAT Mumbai26 Jun 2023AY 2011-12

Bench: Shri Aby T. Varkey () & Ms. Padmavathy S. ()

Section 143(1)Section 147Section 148

supra) has not disturbed the sales figures shown by the assessee and decide accordingly. Needless to say that the assessee be given an opportunity of being heard. 7 ITA 716/Mum/2023 Uttam Ghevvarchand Shrishrimal 8. In the result, the appeal is allowed for statistical purpose. Order pronounced in the open court

Stock Holdings Corporation of India Ltd, Mumbai vs. ACIT 4(2) (1), Mumbai

In the result, the appeal filed by the assessee is dismissed in above terms

ITA 1722/MUM/2021[2017-18]Status: DisposedITAT Mumbai26 Jun 2023AY 2017-18

Bench: Shri Aby T Varkey, Jm & Shri Gagan Goyal, Am

For Appellant: Shri Manish Ajudiya, DRFor Respondent: Shri Akram Khan, AR
Section 143(1)Section 143(1)(a)Section 36(1)(va)

each Ground of Appeal (Rs.) 1 The Commoner of come tax (Appeals) National Faces Appeal Centre erred in passing the order without granting opportunity of being heard to the Appellant. 2 The Appellant submits, had the CITA) granted opportunity of being heard, the Appellant would have demonstrated that the employees

Basanti Auto Agency, Balasore vs. ACIT, Circle Balasore, Balasore

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 109/CTK/2023[2017-18]Status: DisposedITAT Cuttack26 Jun 2023AY 2017-18

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita No.109/Ctk/2023 (ननधाारण वषा / Assessment Year : 2017-2018) Basanti Auto Agency, Vs Acit, Circle-Balasore, Balasore Remuna Golai, Po/Ps: Januganj, Dist: Balasore-756019 Pan No. :Aajts 1630 D (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) ननधााररती की ओर से /Assessee By : Shri P.K.Mishra, Advocate राजस्व की ओर से /Revenue By : Shri S.C.Mohanty, Sr. Dr सुनवाई की तारीख / Date Of Hearing : 26/06/2023 घोषणा की तारीख/Date Of Pronouncement : 26/06/2023 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(A), National Faceless Appeal Centre (Nfac), Delhi, Dated 31.01.2023, Passed In Din & Oder No.Itba/Nfac/S/250/2022- 23/1049270091(1), For The Assessment Year 2017-2018. 2. It Was Submitted By The Ld. Ar Of The Assessee That Two Issues Have Been Raised In The Appeal, One Against The Disallowance Made By Invoking Provisions U/S.40(A)(Ia) Of The Act On The Ground Of Non-Deduction Of Tds U/S.194C. The Second Issue Was Against The Adhoc Disallowance Of 15% Expenses Under Different Heads Totaling To Rs.2,13,330/-. It Was The Submission That In View Of The Decision Of The Hon’Ble Supreme Court In The Case Of R.G.Buildwell Engineers Ltd., 259 Taxman 370 As The Books Of Accounts Have Not Been Rejected, No Adhoc Disallowance Can Be Made.

For Appellant: Shri P.K.Mishra, AdvocateFor Respondent: Shri S.C.Mohanty, Sr. DR
Section 194CSection 40

deducted on such payments, which exceeded the prescribed limit, the issue is restored to the file of AO for readjudication after granting adequate opportunity of being heard. 6. In the result, appeal of the assessee is partly allowed for statistical purposes. Order dictated and pronounced in the open court

Body & Organ Donation Society of India (Bodi), Cuttack vs. CIT (Exemption), Hyderabad

In the result, appeal of the assessee stands allowed for statistical purposes

ITA 100/CTK/2023[2022-23]Status: DisposedITAT Cuttack26 Jun 2023AY 2022-23

Bench: Shri George Mathan & Shri Rajesh Kumarआयकर अऩीऱ सं/Ita No.100/Ctk/2023 (ननधाारण वषा / Assessment Year : 2022-2023) Body & Organ Donation Society Of Vs Cit (Exemption), Hyderabad India (Bodi) Bishnu Vihar, Rajnagarpatna, Gopalpur, Cuttack-753003 Pan No. :Aagab 5267 K (अऩीऱाथी /Appellant) .. (प्रत्यथी / Respondent) ननधााररती की ओर से /Assessee By : Shri S.K.Sarangi, Ca राजस्व की ओर से /Revenue By : Shri M.K.Gautam, Pr.Cit(Osd) सुनवाई की तारीख / Date Of Hearing : 26/06/2023 घोषणा की तारीख/Date Of Pronouncement : 26/06/2023 आदेश / O R D E R Per Bench : This Is An Appeal Filed By The Assessee Against The Order Of The Ld. Cit(E), Hyderabad, Dated 11/03/2023, Passed In Din & Oder No.Itba/Exm/F/Exm45/2022-23/1050630810(1), For The Assessment Year 2022-2023. 3. It Was Submitted By Ld Ar That The Ld Cit(E) Was Not Justified To Reject The Application For Registration U/S.12Aa Of The Act On The Ground Of Non-Submission Of “Form-10Ac & Urn” Issued By The Cpc, Particularly When “Form-10Ac & Urn” Has Not Been Issued & Served On The Assessee. It Was Also The Submission That Proper Opportunity Of Hearing Was Not Granted To The Assessee. It Was The Submission That If One More Opportunity Is Allowed, The Assessee Would Furnish All The Evidences For Disposal Of The Appeal. 4. In Reply, Ld Sr Dr Submitted That Proper Opportunities Were Allowed As Is Evident From The Impugned Order. It Was Submitted That The Order Passed By The Cit(E) Deserves To Be Upheld.

For Appellant: Shri S.K.Sarangi, CAFor Respondent: Shri M.K.Gautam, Pr.CIT(OSD)
Section 12A

appeal. Consequently, the appeal is restored back to the file of the ld CIT(E) for fresh adjudication after granting adequate opportunity of being heard to the assessee. At the same time, we direct the assessee to respond to the notices to be issued

Sri Kailash Chandra Thatoi, Pabitradiha vs. DCIT, Circle-1(1), Sambalpur

In the result, appeal of the assessee stands partly allowed for statistical purposes

ITA 434/CTK/2019[2011-12]Status: DisposedITAT Cuttack26 Jun 2023AY 2011-12

Bench: Before S/Shri George Mathan, Judicial & And Rajesh Kumarassessment Year : 2011-12 Sri Kailash Chandra Thatoi, Ri Kailash Chandra Thatoi, Vs. Dcit, Circle Dcit, Circle -1(1), At:Pabitradiha, Pabitradiha, Cuttack Keonjhargarh, Keonjhar Keonjhargarh, Keonjhar Pan/Gir No. Pan/Gir No.Ablpt 0358 A (Appellant (Appellant) .. ( Respondent Respondent) Assessee By : Shri B.R.Panda, Ar B.R.Panda, Ar Revenue By : Shri S.C.Mohanty, Ld Sr Dr S.C.Mohanty, Ld Sr Dr

For Appellant: Shri B.R.Panda, ARFor Respondent: Shri S.C.Mohanty, ld Sr DR

justice, the issues in the appeal are restored to the file of the Assessing Officer for re-adjudication after granting the assessee adequate opportunity of being heard. Further, it is also directed that the submissions of ld Sr DR also carry weight insofar as the assessee should have been conscious

Rameshbhai Savjibhai Devani, Surat vs. Income Tax Officer, Ward 1(2)(5), Surat

In the result, appeal of the assessee is allowed for statistical purposes in above terms

ITA 65/SRT/2023[2017-18]Status: DisposedITAT Surat26 Jun 2023AY 2017-18

Bench: Shri Pawan Singh, Jm &Dr. A.L.Saini, Am आयकर अपील सं./Ita No.65/Srt/2023 (िनधा"रण वष" / Assessment Year: (2017-18) (Virtual Court Hearing) Rameshbhai Savjibhai Devani Income Tax Officer, 7312/4 G.I.D.C., Road No.7/73, Ward-1(2)(5), Surat, Aaykar Vs. Sachin, Surat-394230 (Gujarat) Bhavan, Majura Gate, Surat- 392001 "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Addpd 4518 N (अपीलाथ" /Appellant ) (""थ"/Respondent)

For Appellant: Shri Rohit Taja, C.AFor Respondent: Shri Vinod Kumar– Sr.DR
Section 143(3)Section 250

note that it is settled law that principles of natural justice and fair play require that the affected party is granted sufficient opportunity of being heard to contest his case. Therefore, we deem it fit and proper to set aside the order of the ld. CIT(A) and remit

Shri Umang Ashokbhai Sundhiya, Surat vs. Income Tax Officer, Ward - 1(3)(9), Surat

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 225/SRT/2023[2017-18]Status: DisposedITAT Surat26 Jun 2023AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.225/Srt/2023 Assessment Year: (2017-18) (Physical Hearing) Shri Umang Ashokbhai Sundhiya, Vs. The Ito, Ward-1(3)(9), 33, 1St Floor, Sneh Smruti Society, Surat. Opp. Dhanmora Complex, Adajan Patia, Surat – 395009. "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Bypps8397J (Assessee) (Respondent) Assessee By Shri Akshay M. Modi, Ca Shri Vinod Kumar, Sr. Dr Respondent By Date Of Hearing 15/06/2023 Date Of Pronouncement 26/06/2023

Section 139(1)Section 142(1)Section 144Section 44A

note that it is settled law that principles of natural justice and fair play require that the affected party is granted sufficient opportunity of being heard to contest his case. Therefore, without delving much deeper into the merits of the case, in the interest of justice, we restore the matter ... back to the file of Assessing Officer for de novo adjudication and pass a speaking order after affording sufficient opportunity of being heard to the assessee, who in turn, is also directed to contest his stand forthwith. Therefore, we deem it fit and proper to ITA.225/SRT/2023/AY.2017-18 Umang Ashokbhai Sundhiya

Sachin Notified Area, Surat vs. Pr. Commissioner of Income Tax, Surat - 1, Surat

In the result, appeal filed by the assessee is allowed

ITA 343/SRT/2022[2017-18]Status: DisposedITAT Surat26 Jun 2023AY 2017-18

Bench: Shri Pawan Singh, Jm & Dr. A. L. Saini, Am आयकर अपील सं./Ita No.343/Srt/2022 "नधा"रण वष"/Assessment Year: (2017-18) (Physical Hearing) Sachin Notified Area, Vs. The Pcit, Surat-1 Plot No.5719, Unnati Building, Sachin Gidc, Sachin, Surat-394230. (Appellant) (Respondent) "थायीलेखासं./जीआइआरसं./Pan/Gir No.: Aaals0146H Shri P. M. Jagasheth, Ca Appellant By Shri Ravinder Sindhu, Cit(Dr) Respondent By Date Of Hearing 31/05/2023 Date Of Pronouncement 26/06/2023

Section 143(3)Section 263

fresh assessment order, consequent to this order under section 263 of the I.T. Act, the Assessing Officer shall grant reasonable and sufficient opportunity of being heard to the assessee.” 15. From the above direction of ld PCIT, it is vivid that ld PCIT has directed to the assessing officer

Archita Burnwal, Jaipur vs. ITO, Ward 1(3), Jaipur

In the result, appeal of the assessee is allowed for statistical purpose

ITA 237/JPR/2023[2010-11]Status: DisposedITAT Jaipur26 Jun 2023AY 2010-11

Bench: DR. S. SEETHALAKSHMI (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Rajat Choudhary (Adv.)For Respondent: Smt. Monisha Choudhary (Addl.CIT) a
Section 144Section 194C

before us we are of the considered view that the assessing officer should hear the assessee’s submission on merits after affording proper opportunity of being heard and passed speaking order in the matter and therefore, the matter is set aside to the file of the learned assessing officer

Ram Kripal Sisodia, Jaipur vs. DCIT, Jaipur

In the result, the appeals of the assessee are allowed for statistical purposes

ITA 110/JPR/2023[2013-14]Status: DisposedITAT Jaipur26 Jun 2023AY 2013-14

Bench: SHRI SANDEEP GOSAIN (Judicial Member), SHRI RATHOD KAMLESH JAYANTBHAI (Accountant Member)

For Appellant: Shri Manish Agarwal, CAFor Respondent: Shri Arvind Kumar, CIT
Section 144Section 69

assessee solely on the basis of information received from ITO (I &CI), without any independent evidences and without providing assessee with adequate opportunity of being heard. 9. On the facts and in the circumstances of the case and in law, ld. CIT(A) has grossly erred in confirming addition made ... assessee solely on the basis of information received from ITO (I & CI)-, Jaipur without any independent evidences and without providing assessee with adequate opportunity of being heard.. Appellant prays that no such investment whatsoever was made by assessee in the name of Shri Ram Dhan Meena nor any evidence

Allied Computers International (Asia) Ltd., Mumbai vs. DCIT, CC-2(2), Mumbai

In the result, the appeal by the assessee is partly allowed for statistical purposes

ITA 687/MUM/2023[2012-13]Status: DisposedITAT Mumbai23 Jun 2023AY 2012-13

Bench: Shri Amarjit Singh & Shri Sandeep Singh Karhail

For Appellant: Shri Neeraj ManglaFor Respondent: Dr. Kishor Dhule
Section 132Section 133(6)Section 142(1)Section 143(3)Section 153CSection 250

claim before the AO regarding this issue without any default. Needless to mention that no order shall be passed without affording reasonable opportunity of being heard to the assessee. In view of the above, the impugned order passed by the learned CIT(A) on this issue is set aside. Accordingly

Tarapur Transformer Ltd., Mumbai vs. ITO Ward-13(3)(1), Mumbai

In the result, appeal filed by the assessee stands allowed for statistical purposes

ITA 1081/MUM/2023[2012-13]Status: DisposedITAT Mumbai23 Jun 2023AY 2012-13

Bench: Shri Om Prakash Kant, Am & Shri N. K. Choudhry, Jm

For Appellant: Sh. Dhananjay Shah, Adv./MsFor Respondent: Sh. B.K. Bagchi, Sr. DR
Section 143(3)Section 250

justice, inclined to remand the instant case to the file of the ld. Commissioner for decision afresh, suffice to say by affording reasonable opportunity of being heard to the assessee. Hence ordered accordingly. The assessee is also directed to appear as and when would be required and to file

Oracle Financial Services Software Limited (Formerly Known As I-Flex Solutions Limited), Mumbai vs. Additional Commissioner of Income Tax Range-8(2), Mumbai

In the result, the appeal of the assessee is partly allowed and the appeal of the revenue is treated as partly allowed

ITA 1473/MUM/2018[2006-07]Status: DisposedITAT Mumbai23 Jun 2023AY 2006-07

Bench: Shri B.R. Baskaran (Am) & Smt. Kavitha Rajagopal (Jm)

Section 10ASection 14A

AO/TPO for examining this issue afresh. 11 Oracle Finance Services Software Limited 12. Needless to mention, the assessee should be given proper opportunity of being heard. 13. In the result, the appeal of the assessee is partly allowed and the appeal of the revenue is treated as partly allowed. Pronounced

Qad India P.Ltd, Mumbai vs. DCIT Cir 9(3), Mumbai

Accordingly, Ground No. 1 raised by the Appellant is disposed off as being general in nature, Ground No. 2 relating to selection of comparables is partly allowed in terms of paragraph 5 to 6

ITA 4098/MUM/2015[2010-11]Status: DisposedITAT Mumbai23 Jun 2023AY 2010-11
For Appellant: Ms. Chandni Shah, Ms. RiddhiFor Respondent: Dr. Samuel Pitta
Section 143(3)Section 234ASection 271(1)(c)Section 92CSection 92C(2)

final set of comparables; re-compute arm’s length price; and transfer pricing adjustment, if any, after giving the Appellant a reasonable opportunity of being heard. Accordingly, Ground No. 1 raised by the Appellant is disposed off as being general in nature, Ground No. 2 relating to selection of comparables