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 High Court quashed the assessment order dated 06.08.2024, holding that the Assessing Authority violated the principles of natural justice by denying an opportunity of personal hearing to the petitioner despite a specific request. Although the show-cause notice indicated 'NA' for personal hearing, the petitioner marked 'Yes' in the reply and sought an opportunity. The Court ruled that any previous opportunity before issuing the show-cause notice was inconsequential. The impending expiry of the limitation period did not justify denying a hearing. The authorities were directed to pass a fresh order after affording an opportunity of hearing to the petitioner.
The High Court quashed the assessment order dated 06.08.2024, holding that the Assessing Authority violated the principles of natural justice by denying an opportunity of personal hearing to the petitioner despite a specific request. Although the show-cause notice indicated 'NA' for personal hearing, the petitioner marked 'Yes' in the reply and sought an opportunity. The Court ruled that any previous opportunity before issuing the show-cause notice was inconsequential. The impending expiry of the limitation period did not justify denying a hearing. The authorities were directed to pass a fresh order after affording an opportunity of hearing to the petitioner.
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