Allowing the petition the Court held that the Assessing Officer had made a proposal dated December 24, 2019 in a great hurry after issuing notice under section 142(1) calling upon the assessee to furnish the accounts and documents specified on or before December 24, 2019 at 12: 15 p.m. Such notice was admittedly issued at 10:03 p. m. on December 23. fixing the date of hearing on December 24, 2019. However, there was no response from the assessee and none had attended. Reasons for making transfer was also recorded on December 24, 2019 and thereafter the Principal Commissioner had granted approval also on December 24, 2019. The assessee was never provided any opportunity to make submissions in response to the notice dated December 23, 2019. In such circumstances, the further opportunity of hearing granted on December 23, 2019 was only an empty formality resulting into breach of principles of natural justice. The reference made by the Assessing Officer under section 92CA(3) to the Transfer Pricing Officer and the approval granted by the Principal Commissioner were quashed and set aside. The proceedings were remitted to the Assessing Officer for fresh consideration of the matter to pass a fresh de novo reasoned order after giving an opportunity of hearing to the assessee and considering the objections in accordance with law.(AY. 2017-18)