Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Violation of principles of natural justice - notice u/s 46 was not been given to the petitioner - The Court rejects the petitioner's contention regarding non-compliance with Section 46. Since the petitioner filed a NIL return, no notice was necessary under this section. The case falls under Chapter XIV, where notices were issued under Section 70 post-search and seizure. - The Court finds no violation of principles of natural justice. The petitioner was provided with opportunities for a personal hearing, as mandated by Section 75(5) of the Act. The petitioner's admission of GST liability in evidence strengthens this finding. - Consequently, the writ petition was dismissed, with the petitioner directed to pursue appellate remedies.
Violation of principles of natural justice - notice u/s 46 was not been given to the petitioner - The Court rejects the petitioner's contention regarding non-compliance with Section 46. Since the petitioner filed a NIL return, no notice was necessary under this section. The case falls under Chapter XIV, where notices were issued under Section 70 post-search and seizure. - The Court finds no violation of principles of natural justice. The petitioner was provided with opportunities for a personal hearing, as mandated by Section 75(5) of the Act. The petitioner's admission of GST liability in evidence strengthens this finding. - Consequently, the writ petition was dismissed, with the petitioner directed to pursue appellate remedies.
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