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 HC held that u/s 74(1), the authority can issue a single notice calling upon the assessee to pay tax not paid, short paid, erroneously refunded, or where input tax credit was wrongly availed due to fraud, misstatement or suppression of facts, for any period, provided the notice is given at least 6 months prior to the time limit specified in Section 74(10). The petitioner's argument that separate notices should have been issued for each financial year was rejected. The petition challenging the show cause notice was dismissed, allowing the petitioner to raise all arguments before the concerned authority.
The HC held that u/s 74(1), the authority can issue a single notice calling upon the assessee to pay tax not paid, short paid, erroneously refunded, or where input tax credit was wrongly availed due to fraud, misstatement or suppression of facts, for any period, provided the notice is given at least 6 months prior to the time limit specified in Section 74(10). The petitioner's argument that separate notices should have been issued for each financial year was rejected. The petition challenging the show cause notice was dismissed, allowing the petitioner to raise all arguments before the concerned authority.
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