https://www.taxtmi.com/caselaws?id=798034 Service of a show cause notice and an opportunity of hearing are mandatory before the Transfer Pricing Officer determines arm's length price under Section 92CA(3) read with Section 92C(3). Information notices issued during transfer-pricing proceedings do not substitute for the statutory notice requiring the assessee to respond to a proposed adjustment. Non-service of that notice deprives the assessee of the required hearing and invalidates the arm's length price determination. The determination must therefore be set aside and reconsidered only after proper notice and hearing. en-us Tue, 25 Aug 2026 00:00:00 +0530 Tue, 01 Sep 2026 08:26:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=798034 Service of a show cause notice and an opportunity of hearing are mandatory before the Transfer Pricing Officer determines arm's length price under Section 92CA(3) read with Section 92C(3). Information notices issued during transfer-pricing proceedings do not substitute for the statutory notice requiring the assessee to respond to a proposed adjustment. Non-service of that notice deprives the assessee of the required hearing and invalidates the arm's length price determination. The determination must therefore be set aside and reconsidered only after proper notice and hearing. Case-Laws Income Tax Tue, 25 Aug 2026 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=798034