Principles of natural justice breached where assessment ignored taxpayer replies to new comparables, requiring remand for fresh consideration.

An assessment-related order issued after proposing new transfer pricing comparables under Section 92C(3) was held vitiated by breach of the principles of natural justice because the officer proceeded without considering the taxpayer's replies and without granting adequate time to collate and supply additional comparable materials; the taxpayer had filed partial responses and later submitted sector-specific data which was not referred to. Outcome: the impugned order is set aside and the matter remanded for fresh examination after affording a proper opportunity to reply, with a fresh order to be passed within three months.

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Issues: Whether the impugned order dated 11th September, 2025 passed by the Transfer Pricing Officer is vitiated by a breach of the principles of natural justice for failing to consider the petitioner's replies and for not giving adequate time to collate material in respect of newly proposed comparables under Section 92C(3) of the Income-tax Act, 1961.

Analysis: The Transfer Pricing Officer issued a show cause notice proposing new comparables under Section 92C(3). The petitioner furnished a partial reply and sought time to collate additional material relevant to the newly proposed comparables. The petitioner subsequently filed material for the "ITes" sector and later provided materials for the "IT" sector, but the impugned order was passed without referring to or considering the reply filed on 8th September, 2025 or affording adequate opportunity to supply and have considered the additional information. The factual sequence shows that the petitioner's submissions and collated material were not given consideration before passing the assessment-related order, resulting in a denial of a meaningful opportunity to be heard.

Conclusion: The impugned order is set aside on the ground of breach of the principles of natural justice. The matter is remanded to the Transfer Pricing Officer to examine the issue afresh after giving the petitioner an opportunity to reply to the show cause notice dated 18th August, 2025, and pass a fresh order within three months.

Ratio Decidendi: An assessment-related order passed without giving adequate time to collate and consider material filed in response to a show cause notice proposing new comparables under Section 92C(3) of the Income-tax Act, 1961, constitutes a breach of the principles of natural justice and vitiates the order, requiring remand for fresh consideration.

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