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 - Mode of Communication - petitioner submits that in most of the cases, the assessees are not aware of the show cause notices and assessment orders due to lack of communication through post - The Court recognized the petitioner's argument regarding the lack of awareness among traders regarding electronic communications. It emphasized the importance of providing adequate opportunity to taxpayers, suggesting that notices should also be issued through postal services and in regional languages to facilitate better understanding and response. - The Court noted the petitioner's assertion regarding the Department's failure to adhere to prescribed procedures. - It emphasized the importance of fair procedures and providing sufficient opportunity to taxpayers before passing adverse orders.
Violation of principles of natural justice - Mode of Communication - petitioner submits that in most of the cases, the assessees are not aware of the show cause notices and assessment orders due to lack of communication through post - The Court recognized the petitioner's argument regarding the lack of awareness among traders regarding electronic communications. It emphasized the importance of providing adequate opportunity to taxpayers, suggesting that notices should also be issued through postal services and in regional languages to facilitate better understanding and response. - The Court noted the petitioner's assertion regarding the Department's failure to adhere to prescribed procedures. - It emphasized the importance of fair procedures and providing sufficient opportunity to taxpayers before passing adverse orders.
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