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...
Validity of assessment proceedings - opportunity of hearing not provided - applicability of Section 75 of TN Goods and ST Act - it is adverse to the writ petitioner as it proceeds on the basis that writ petitioner has suppressed transactions and more importantly, penalty has also been levied. Therefore, the argument that the opportunity of hearing was not given as the writ petitioner, who is the person chargeable with tax, has not chosen to make a written request, does not hold water. - HC
Validity of assessment proceedings - opportunity of hearing not provided - applicability of Section 75 of TN Goods and ST Act - it is adverse to the writ petitioner as it proceeds on the basis that writ petitioner has suppressed transactions and more importantly, penalty has also been levied. Therefore, the argument that the opportunity of hearing was not given as the writ petitioner, who is the person chargeable with tax, has not chosen to make a written request, does not hold water. - HC
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