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    <title>2020 (1) TMI 1744 - ITAT MUMBAI</title>
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    <description>Where objections to the draft assessment were filed beyond the 30-day period, the DRP rejected them as time-barred, leaving the AO to pass the final order u/s 144C(3) without DRP directions; however, the transfer pricing determination was vitiated because the TPO altered the assessee&#039;s transfer pricing method without issuing a show-cause notice or affording reasonable opportunity, contrary to principles of natural justice reflected in the order u/s 92CA(3). Consequently, the transfer pricing issue and resultant assessment were set aside and remanded to the AO/TPO for fresh adjudication after due opportunity, and the appeal was allowed for statistical purposes.</description>
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      <title>2020 (1) TMI 1744 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=465780</link>
      <description>Where objections to the draft assessment were filed beyond the 30-day period, the DRP rejected them as time-barred, leaving the AO to pass the final order u/s 144C(3) without DRP directions; however, the transfer pricing determination was vitiated because the TPO altered the assessee&#039;s transfer pricing method without issuing a show-cause notice or affording reasonable opportunity, contrary to principles of natural justice reflected in the order u/s 92CA(3). Consequently, the transfer pricing issue and resultant assessment were set aside and remanded to the AO/TPO for fresh adjudication after due opportunity, and the appeal was allowed for statistical purposes.</description>
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