Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Denial of a personal hearing before adverse GST assessment was held to violate principles of natural justice and the hearing requirement under Section 75(4). Although there was a dispute about the assessing officer's physical availability, the attendance register showed that the authorised representative attended, reiterated the reply, and expressly sought another hearing before any negative order. The Court treated the unanswered request for personal hearing as determinative, set aside the assessment orders, and remanded the matters for fresh decision after granting an opportunity of personal hearing.
Denial of a personal hearing before adverse GST assessment was held to violate principles of natural justice and the hearing requirement under Section 75(4). Although there was a dispute about the assessing officer's physical availability, the attendance register showed that the authorised representative attended, reiterated the reply, and expressly sought another hearing before any negative order. The Court treated the unanswered request for personal hearing as determinative, set aside the assessment orders, and remanded the matters for fresh decision after granting an opportunity of personal hearing.
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