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 due to errors apparent on record. Petitioner claimed inability to respond or participate due to unawareness of proceedings. Court held that tax computation erred by considering total turnover instead of turnover difference between profit and loss account and GSTR 9. Petitioner's explanation of unawareness unacceptable for a large corporate entity. However, substantial liability imposed without considering GSTR 9C reconciliation statement. Cumulatively, opportunity granted to petitioner to contest tax demand by remitting Rs.2.50 crore within four weeks and submitting reply with relevant documents. Impugned order set aside subject to compliance. Petition disposed of.
Principles of natural justice violated due to errors apparent on record. Petitioner claimed inability to respond or participate due to unawareness of proceedings. Court held that tax computation erred by considering total turnover instead of turnover difference between profit and loss account and GSTR 9. Petitioner's explanation of unawareness unacceptable for a large corporate entity. However, substantial liability imposed without considering GSTR 9C reconciliation statement. Cumulatively, opportunity granted to petitioner to contest tax demand by remitting Rs.2.50 crore within four weeks and submitting reply with relevant documents. Impugned order set aside subject to compliance. Petition disposed of.
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