2016 (5) TMI 1523

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....eeja and Mr Gautam Swarup, Advocates For The Petitioner. Mr P. Roychaudhuri, Advocates for The Respondent. This writ petition pertains to the order passed by the TPO dated 29.03.2016 in respect of the Assessment Year 2008-09. The TPO had utilized purported segmental data of several companies for the purposes of arriving at the arms' length price, as indicated in the impugned order. The griev....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....t no opportunity of cross-examination of the authorized personnel, who had provided the segmental data, was granted to the petitioner. When reliance is placed on the data provided by different parties, the petitioner would have had no opportunity of rebutting the data unless the persons, who submitted the data, were subjected to cross-examination. This is all the more so because the data that w....