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Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Violation of principles of natural justice occurred as the impugned SCN was uploaded under 'View Additional Notices & Orders' category, claimed to be inaccessible by petitioner. Court held that issue was covered by earlier decisions rejecting contention that uploading notices under 'Additional Notices' constituted sufficient service u/s 169 of CGST Act, 2017. GST Authorities redesigned portal to ensure 'View Notices' and 'View Additional Notices' tabs are adjacent. Impugned SCN was issued before portal redesign. Petition allowed, impugned order set aside, matter remanded for fresh adjudication of SCN.
Violation of principles of natural justice occurred as the impugned SCN was uploaded under 'View Additional Notices & Orders' category, claimed to be inaccessible by petitioner. Court held that issue was covered by earlier decisions rejecting contention that uploading notices under 'Additional Notices' constituted sufficient service u/s 169 of CGST Act, 2017. GST Authorities redesigned portal to ensure 'View Notices' and 'View Additional Notices' tabs are adjacent. Impugned SCN was issued before portal redesign. Petition allowed, impugned order set aside, matter remanded for fresh adjudication of SCN.
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