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...
Petition maintainable - violation of Section 75(4) of UPGST Act - denial of opportunity of personal hearing - violation of principles of natural justice. Opportunity of personal hearing must be provided before assessment/adjudication order against assessee. Neither adjudicating authority issued notice for personal hearing nor granted opportunity to petitioner. Before adverse order in adjudication, personal hearing must be offered to noticee. If waived, authority may proceed ex-parte. Inordinate delay of five years in passing impugned order violates natural justice. Impugned order passed in gross violation of natural justice - unsustainable, petition allowed.
Petition maintainable - violation of Section 75(4) of UPGST Act - denial of opportunity of personal hearing - violation of principles of natural justice. Opportunity of personal hearing must be provided before assessment/adjudication order against assessee. Neither adjudicating authority issued notice for personal hearing nor granted opportunity to petitioner. Before adverse order in adjudication, personal hearing must be offered to noticee. If waived, authority may proceed ex-parte. Inordinate delay of five years in passing impugned order violates natural justice. Impugned order passed in gross violation of natural justice - unsustainable, petition allowed.
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