Tribunal excluded three companies from comparable list without giving an opportunity to the assessee to counter argue against exclusion of comparable .On appeal High Court remanded back to consider whether said companies were comparable or not . ( AY. 2010-11 )
Jacob Engineering India ( P)Ltd v. ACIT ( 2022) 285 Taxman 326 ( Bom)( HC)
S. 92C : Transfer pricing – Arm’s length price -Comparable – Opportunity of hearing was not given – Matter remanded [ S. 254(1) ]