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...
Service of GST notices after cancellation of registration must be effective, and an adverse adjudication requires a meaningful opportunity to reply and a personal hearing. Where registration had been cancelled and the taxpayer was not effectively served or heard, the adjudication order was quashed. The taxpayer was permitted to file a reply to the show-cause notice, and the Department could undertake fresh adjudication in accordance with law after granting a personal hearing.
Service of GST notices after cancellation of registration must be effective, and an adverse adjudication requires a meaningful opportunity to reply and a personal hearing. Where registration had been cancelled and the taxpayer was not effectively served or heard, the adjudication order was quashed. The taxpayer was permitted to file a reply to the show-cause notice, and the Department could undertake fresh adjudication in accordance with law after granting a personal hearing.
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