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Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Violation of principles of natural justice (audi alterem partem) - In the present case, when the petitioner had cancelled its registration in the year 2019, a proper notice was required to be issued to it u/s 74 of the Act at its address. However, the authorities simply uploaded the Section 74 show cause notice on the web portal inspite of knowing that the petitioner had already cancelled its registration prior to the date of issuance of the show cause notice. This action clearly prevented the petitioner from appearing in the hearing in the original proceeding u/s 74 of the Act that was accordingly passed ex parte - HC
Violation of principles of natural justice (audi alterem partem) - In the present case, when the petitioner had cancelled its registration in the year 2019, a proper notice was required to be issued to it u/s 74 of the Act at its address. However, the authorities simply uploaded the Section 74 show cause notice on the web portal inspite of knowing that the petitioner had already cancelled its registration prior to the date of issuance of the show cause notice. This action clearly prevented the petitioner from appearing in the hearing in the original proceeding u/s 74 of the Act that was accordingly passed ex parte - HC
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