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...
Impugned orders were passed against petitioner without serving show cause notice or providing opportunity for personal hearing, violating principles of natural justice. Mere uploading of notices on GST Portal under 'View Notice and Orders' and 'View Additional Notices and Orders' tabs cannot be deemed sufficient service. As a small concern, petitioner was unaware of notices on portal until contacted by department. Orders passed ex parte without hearing petitioner are unsustainable and violate Articles 14 and 19(1)(g) of Constitution. Impugned orders set aside and matter remanded to department for fresh consideration after providing opportunity to petitioner.
Impugned orders were passed against petitioner without serving show cause notice or providing opportunity for personal hearing, violating principles of natural justice. Mere uploading of notices on GST Portal under 'View Notice and Orders' and 'View Additional Notices and Orders' tabs cannot be deemed sufficient service. As a small concern, petitioner was unaware of notices on portal until contacted by department. Orders passed ex parte without hearing petitioner are unsustainable and violate Articles 14 and 19(1)(g) of Constitution. Impugned orders set aside and matter remanded to department for fresh consideration after providing opportunity to petitioner.
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