Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Effective service of GST notices requires more than portal uploading where a taxpayer remains non-responsive despite repeated reminders. Although portal upload constitutes valid service, the assessing officer should consider other statutory modes, preferably registered post with acknowledgement due, to ensure actual communication before making an ex parte assessment. Failure to provide a meaningful opportunity of personal hearing can invalidate the assessment. The High Court set aside the ex parte assessment and lifted the consequential attachment, remanding the matter for fresh merits consideration subject to payment of 25% of the disputed tax. The taxpayer may file objections, and the officer must give clear 14 days' notice of personal hearing.
Effective service of GST notices requires more than portal uploading where a taxpayer remains non-responsive despite repeated reminders. Although portal upload constitutes valid service, the assessing officer should consider other statutory modes, preferably registered post with acknowledgement due, to ensure actual communication before making an ex parte assessment. Failure to provide a meaningful opportunity of personal hearing can invalidate the assessment. The High Court set aside the ex parte assessment and lifted the consequential attachment, remanding the matter for fresh merits consideration subject to payment of 25% of the disputed tax. The taxpayer may file objections, and the officer must give clear 14 days' notice of personal hearing.
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