TMI Blog2008 (10) TMI 376X X X X Extracts X X X X X X X X Extracts X X X X ..... ated that due to short time that has been allowed for filing reply, the petitioner could not place all the documents on which the petitioner wish to rely upon and could not submit his complete reply - Held that: - The submission made on behalf of the respondents that the petitioner at the rehearing of the matter should not be given an opportunity to file additional reply, wherein he may change his ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... er section 92CA(3) by the Transfer Pricing Officer - I(4), Mumbai determining the transfer price and directing the assessment officer to make addition of Rs. 362,29,41,000 in the income of the petitioner. The grievance of the petitioner against that order, which is impugned before us is that the show-cause notice was issued to the petitioner on 21-2-2008. He was to file reply by 29-2-2008. The pet ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4. After hearing the matter on last occasion, we had asked the learned counsel for the respondents to take instructions whether in this view of the matter, the matter can be reheard by the authority. The learned counsel for the respondents, after taking instructions stated that the respondents is willing to give personal hearing to the petitioner and will pass fresh order after granting personal ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... itioner to change his stand, in our opinion, neither the department nor this Court would be justified in denying the petitioner an opportunity to change his stand. Any contention that the petitioner may raise have to be dealt with in accordance with law and if according to the respondents, the petitioner is not entitled to change his stand in law, the respondents can make an order accordingly but ..... X X X X Extracts X X X X X X X X Extracts X X X X
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