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...
Principles of natural justice violated. Respondent disregarded petitioner's clarifications, GSTR 9 reconciliation, audited balance sheet, confirming show cause notice allegations through impugned order citing "incomplete documents" despite discrepancies in GSTR 1 and GSTR 3B filings. High Court held show cause notice issued 28.12.2023, petitioner filed reply 11.03.2024 with final reconciliation, E-Way bill turnover reconciliation with GSTR-1 and seven supporting documents, but respondent mechanically passed impugned order without considering reply. Impugned order set aside, matter remitted to respondent to consider reply, reconciliations, documents, provide personal hearing opportunity, and pass detailed speaking order. Petition disposed by way of remand.
Principles of natural justice violated. Respondent disregarded petitioner's clarifications, GSTR 9 reconciliation, audited balance sheet, confirming show cause notice allegations through impugned order citing "incomplete documents" despite discrepancies in GSTR 1 and GSTR 3B filings. High Court held show cause notice issued 28.12.2023, petitioner filed reply 11.03.2024 with final reconciliation, E-Way bill turnover reconciliation with GSTR-1 and seven supporting documents, but respondent mechanically passed impugned order without considering reply. Impugned order set aside, matter remitted to respondent to consider reply, reconciliations, documents, provide personal hearing opportunity, and pass detailed speaking order. Petition disposed by way of remand.
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