https://www.taxtmi.com/caselaws?id=330767 HC set aside three references made by the AO to the TPO for AYs 2011-12, 2012-13 and 2013-14 because the AO proceeded without affording the assessee an opportunity of being heard. The court held the AO must either determine ALP under s.92C(3) or refer to the TPO under s.92CA(1) but must provide a hearing before recording satisfaction; CBDT Instruction No.3 of 2016 applies as a procedural safeguard and required application in this case. en-us Mon, 25 Jul 2016 00:00:00 +0530 Fri, 07 Nov 2025 18:32:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=330767 HC set aside three references made by the AO to the TPO for AYs 2011-12, 2012-13 and 2013-14 because the AO proceeded without affording the assessee an opportunity of being heard. The court held the AO must either determine ALP under s.92C(3) or refer to the TPO under s.92CA(1) but must provide a hearing before recording satisfaction; CBDT Instruction No.3 of 2016 applies as a procedural safeguard and required application in this case. Case-Laws Income Tax Mon, 25 Jul 2016 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=330767