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 court held that u/s 75(4) of the GST Act, an opportunity for personal hearing must be granted if requested in writing by the person liable for tax or penalty, or if an adverse decision is contemplated against such person. However, if the person chooses not to appear before the authority after receiving the show-cause notice, neither filing a reply nor requesting a personal hearing, then after the final order is passed, they cannot claim that an opportunity for hearing was denied. The court dismissed the writ petition, upholding the principle that a personal hearing is an entitlement only when requested, and not providing it cannot be grounds for challenging the order if the person failed to make such a request.
The court held that u/s 75(4) of the GST Act, an opportunity for personal hearing must be granted if requested in writing by the person liable for tax or penalty, or if an adverse decision is contemplated against such person. However, if the person chooses not to appear before the authority after receiving the show-cause notice, neither filing a reply nor requesting a personal hearing, then after the final order is passed, they cannot claim that an opportunity for hearing was denied. The court dismissed the writ petition, upholding the principle that a personal hearing is an entitlement only when requested, and not providing it cannot be grounds for challenging the order if the person failed to make such a request.
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