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...
The High Court found a violation of the principles of natural justice due to the Assessing Authority's denial of an oral hearing opportunity. The court held that even if the petitioner did not request a personal hearing, the Authority must still provide it before making an adverse decision, especially in cases with significant civil liability. Upholding the principle of natural justice, the Court emphasized the necessity of a genuine opportunity for hearing before rejecting explanations and imposing demands. The case was remitted to the Assistant Commissioner to issue a fresh notice to the petitioner within two weeks for a proper hearing.
The High Court found a violation of the principles of natural justice due to the Assessing Authority's denial of an oral hearing opportunity. The court held that even if the petitioner did not request a personal hearing, the Authority must still provide it before making an adverse decision, especially in cases with significant civil liability. Upholding the principle of natural justice, the Court emphasized the necessity of a genuine opportunity for hearing before rejecting explanations and imposing demands. The case was remitted to the Assistant Commissioner to issue a fresh notice to the petitioner within two weeks for a proper hearing.
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