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 dismissed the petition challenging the show cause notice issued u/s 74 of the Central Goods and Services Tax Act, 2017. The court found no justification for alleging suppression or invoking the extended period of limitation. The show cause notice was based on findings from investigations after the audit report. The petitioner's statements accepting its status as a payment aggregator were considered relevant. The court held that at the show cause notice stage, judicial review is extremely narrow, and defences can be raised in response. Interference is warranted only in cases of violation of fundamental rights, natural justice, or lack of jurisdiction, which were not established here. The petitioner was directed to respond to the show cause notice and raise all defences.
The High Court dismissed the petition challenging the show cause notice issued u/s 74 of the Central Goods and Services Tax Act, 2017. The court found no justification for alleging suppression or invoking the extended period of limitation. The show cause notice was based on findings from investigations after the audit report. The petitioner's statements accepting its status as a payment aggregator were considered relevant. The court held that at the show cause notice stage, judicial review is extremely narrow, and defences can be raised in response. Interference is warranted only in cases of violation of fundamental rights, natural justice, or lack of jurisdiction, which were not established here. The petitioner was directed to respond to the show cause notice and raise all defences.
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