Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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Refund claim - Adjustment of amount against outstanding demand - Refunds have been adjusted against the outstanding tax demand by the Authority without following the procedure prescribed under Section 245 of the Act, inasmuch as no notice or opportunity of pre-decisional hearing had been provided to the Petitioner prior to such adjustment of refund in excess of 20% - the Petitioner is entitled to refund of adjustments made in excess of 20% of the disputed tax demands. - HC
Refund claim - Adjustment of amount against outstanding demand - Refunds have been adjusted against the outstanding tax demand by the Authority without following the procedure prescribed under Section 245 of the Act, inasmuch as no notice or opportunity of pre-decisional hearing had been provided to the Petitioner prior to such adjustment of refund in excess of 20% - the Petitioner is entitled to refund of adjustments made in excess of 20% of the disputed tax demands. - HC
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