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...
Denial of specific request for personal hearing - The High Court noted that the petitioner had indeed expressed a legitimate difficulty in availing the opportunity for a personal hearing through video conference due to technical issues with the web portal. Referring to a previous judgment, the Court emphasized that the mere failure to click on the request button should not preclude the petitioner from being granted a personal hearing, especially when the petitioner had explicitly requested it in written submissions. - Consequently, the Court set aside the impugned assessment order and directed that the assessment be framed after affording the petitioner a reasonable opportunity for a personal hearing through video conference within a specified timeframe.
Denial of specific request for personal hearing - The High Court noted that the petitioner had indeed expressed a legitimate difficulty in availing the opportunity for a personal hearing through video conference due to technical issues with the web portal. Referring to a previous judgment, the Court emphasized that the mere failure to click on the request button should not preclude the petitioner from being granted a personal hearing, especially when the petitioner had explicitly requested it in written submissions. - Consequently, the Court set aside the impugned assessment order and directed that the assessment be framed after affording the petitioner a reasonable opportunity for a personal hearing through video conference within a specified timeframe.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
