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...
Effective service of a show cause notice requires more than a portal display: if the notice is not placed in the prescribed "View Notices and Orders" window and no copy is separately served, the recipient is denied a reasonable opportunity to reply. Absence of a personal hearing before adjudication further breaches natural justice and vitiates the consequential order. Where the defect goes to procedural fairness, the High Court may entertain writ jurisdiction despite an alternate appellate remedy, quash the notice and order, and remit the matter for fresh adjudication after reply and hearing.
Effective service of a show cause notice requires more than a portal display: if the notice is not placed in the prescribed "View Notices and Orders" window and no copy is separately served, the recipient is denied a reasonable opportunity to reply. Absence of a personal hearing before adjudication further breaches natural justice and vitiates the consequential order. Where the defect goes to procedural fairness, the High Court may entertain writ jurisdiction despite an alternate appellate remedy, quash the notice and order, and remit the matter for fresh adjudication after reply and hearing.
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