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...
The petition was declined on grounds of maintainability due to availability of an alternate efficacious remedy of appeal against the impugned order. The contention regarding failure of principles of natural justice due to lack of opportunity of hearing was rejected, as intimations were sent to the petitioner's registered address, and the petitioner failed to notify the change of address. It was held that it was a case of "no adequate notice" rather than "no notice," and in such cases, the party must establish prejudice. Consequently, the petitioner was relegated to avail the alternate remedy of appeal, and the petition was disposed of.
The petition was declined on grounds of maintainability due to availability of an alternate efficacious remedy of appeal against the impugned order. The contention regarding failure of principles of natural justice due to lack of opportunity of hearing was rejected, as intimations were sent to the petitioner's registered address, and the petitioner failed to notify the change of address. It was held that it was a case of "no adequate notice" rather than "no notice," and in such cases, the party must establish prejudice. Consequently, the petitioner was relegated to avail the alternate remedy of appeal, and the petition was disposed of.
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