Natural justice in transfer-pricing proceedings requires a personal hearing and reasoned consideration of written objections before determination.

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....Natural justice in transfer-pricing proceedings requires a personal hearing, reasoned findings, and meaningful consideration of written submissions. Although the transfer-pricing order recorded that written replies had been considered, it neither disclosed that a personal hearing was granted nor addressed the contentions raised. The cryptic and unreasoned order was set aside, with directions for a fresh reasoned determination after a personal hearing. The time for completing the assessment was extended.....