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...
Challenge to demand-cum-show-cause - no opportunity for written explanation - violation of natural justice. Writ Court typically doesn't entertain challenges to show-cause notices as they don't affect parties' rights immediately. Show-cause notices can be challenged if issuing authority lacks jurisdiction. Supreme Court in SPECIAL DIRECTOR VERSUS MOHD. GHULAM GHOUSE emphasized jurisdictional issues can be raised before approaching Court. Interim orders shouldn't strip authorities of decision-making power. Following this, writ appeal rejected, petitioner advised to respond to notice and raise contentions before authorities for consideration. Appeal dismissed by High Court.
Challenge to demand-cum-show-cause - no opportunity for written explanation - violation of natural justice. Writ Court typically doesn't entertain challenges to show-cause notices as they don't affect parties' rights immediately. Show-cause notices can be challenged if issuing authority lacks jurisdiction. Supreme Court in SPECIAL DIRECTOR VERSUS MOHD. GHULAM GHOUSE emphasized jurisdictional issues can be raised before approaching Court. Interim orders shouldn't strip authorities of decision-making power. Following this, writ appeal rejected, petitioner advised to respond to notice and raise contentions before authorities for consideration. Appeal dismissed by High Court.
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