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...
Non-consideration of reply given pursuant to GST DRC-01A notice violates principles of natural justice. Rule 142(1A) merely allows proper officer discretion to issue communication, not adjudicate submissions. Right of assessee arises only after show cause notice u/r 142(1)(a) with hearing opportunity. Affording hearing at different stages not contemplated by legislature. Taxing statutes strictly construed without implying equity or hardship considerations. Since only communication issued, no grounds to entertain writ petition filed to stall pending proceedings. Writ petition dismissed.
Non-consideration of reply given pursuant to GST DRC-01A notice violates principles of natural justice. Rule 142(1A) merely allows proper officer discretion to issue communication, not adjudicate submissions. Right of assessee arises only after show cause notice u/r 142(1)(a) with hearing opportunity. Affording hearing at different stages not contemplated by legislature. Taxing statutes strictly construed without implying equity or hardship considerations. Since only communication issued, no grounds to entertain writ petition filed to stall pending proceedings. Writ petition dismissed.
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