2026 (3) TMI 233

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

.... For the Petitioner: Mr. Porus F. Kaka, Sr. Advocate with Adv. Manish Kanth i/b. Adv. Atul K. Jasani,. For the Respondents: Adv. Shilpa Goyal,. P.C. 1. The above Writ Petition is filed to set aside the Order dated 11th September, 2025 passed by Respondent No. 1 (the Transfer Pricing Officer) for Assessment Year 2023-24. 2. The short ground on which the above Order is assailed is that....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....r was concerned, the material was yet to be collated. 5. Without considering the reply filed on 8th September, 2025 or giving the Petitioner an opportunity to collate the material in relation to the "IT" Sector, the impugned Order is passed. 6. Ms. Goyal, the learned Counsel appearing on behalf of the Revenue, did not dispute this factual position and submitted that appropriate orders be pas....

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

...., the Petitioner has, in fact, given the material to the Transfer Pricing Officer, though after passing of the impugned order, i.e. on 22nd September, 2025. When we looks at these facts, we find that there is a breach of the principles of natural justice, and hence, the impugned order cannot be sustained. It is, therefore, set aside. The matter is now remanded back to the Transfer Pricing Officer ....