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...
Violation of principles of natural justice - Validity of assessment order - As adverse orders would have been passed against the petitioner, it was incumbent on the part of the respondents to issue a notice of personal hearing to the petitioner. Though in this case, admittedly the petitioner had filed the reply belatedly on 16.08.2021 having considered the reply and having decided to pass an adverse order, it was incumbent on the part of the respondents to call upon the petitioner for a personal hearing. - Matter restored back - HC
Violation of principles of natural justice - Validity of assessment order - As adverse orders would have been passed against the petitioner, it was incumbent on the part of the respondents to issue a notice of personal hearing to the petitioner. Though in this case, admittedly the petitioner had filed the reply belatedly on 16.08.2021 having considered the reply and having decided to pass an adverse order, it was incumbent on the part of the respondents to call upon the petitioner for a personal hearing. - Matter restored back - HC
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4803
Join Channel
TaxTMI 
