The Tribunal held that assessee was not allowed sufficient opportunity of hearing. The transfer pricing adjustment was to be set aside and the issue restored to the Assessing Officer/the Transfer Pricing Officer for proper consideration after allowing sufficient opportunity of hearing to the assessee. (AY. 2013-14)
United Spirits Ltd. v. Dy. CIT (2022) 97 ITR 272 (Bang)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Purchase of raw material from associate enterprise-Assessee denied opportunity of hearing before Dispute Resolution Panel-Order set aside and remanded. [S. 92CA]