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...
Demand u/s 74 - violation of principles of natural justice - The High court noted that Section 75(4) of the CGST Act mandates that an opportunity for hearing must be granted either when a specific request is received in writing from a person chargeable with tax or when any adverse decision is contemplated against such a person. The court found that even if the petitioners did not specifically request a personal hearing, they were entitled to one since an adverse decision was contemplated against them.
Demand u/s 74 - violation of principles of natural justice - The High court noted that Section 75(4) of the CGST Act mandates that an opportunity for hearing must be granted either when a specific request is received in writing from a person chargeable with tax or when any adverse decision is contemplated against such a person. The court found that even if the petitioners did not specifically request a personal hearing, they were entitled to one since an adverse decision was contemplated against them.
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