Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
The High Court examined the validity of an assessment order issued without offering a personal hearing, deeming it a breach of natural justice. The case was transferred from the National Faceless Assessment Center to the jurisdictional AO u/s 144B(8). The respondent rejected the petitioner's request for a hearing via video conference due to purported lack of functionality, contrary to provisions in section 144B and a CBDT circular. The court found the respondent's claim baseless as the circular mandated a hearing either via video conference or in a designated area. The petitioner's right to a hearing was upheld, dismissing the respondent's argument of alternative appeal options. The assessment order was annulled, and the matter was remanded for a proper hearing in line with the CBDT circular.
The High Court examined the validity of an assessment order issued without offering a personal hearing, deeming it a breach of natural justice. The case was transferred from the National Faceless Assessment Center to the jurisdictional AO u/s 144B(8). The respondent rejected the petitioner's request for a hearing via video conference due to purported lack of functionality, contrary to provisions in section 144B and a CBDT circular. The court found the respondent's claim baseless as the circular mandated a hearing either via video conference or in a designated area. The petitioner's right to a hearing was upheld, dismissing the respondent's argument of alternative appeal options. The assessment order was annulled, and the matter was remanded for a proper hearing in line with the CBDT circular.
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