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...
HC allowed petition - Assessing officer's order violated principles of natural justice by denying opportunity to petitioner to present defense - Failure to serve show cause notice rendered proceedings flawed - Appeal remedy denied due to delay caused by lack of knowledge of order - Procedural requirements mandatory, non-compliance invalidates actions - Fair opportunity must be given to all parties - Appeal timelines to consider actual knowledge of orders - Assessing officer's order treated as show cause notice to enable petitioner to file objections.
HC allowed petition - Assessing officer's order violated principles of natural justice by denying opportunity to petitioner to present defense - Failure to serve show cause notice rendered proceedings flawed - Appeal remedy denied due to delay caused by lack of knowledge of order - Procedural requirements mandatory, non-compliance invalidates actions - Fair opportunity must be given to all parties - Appeal timelines to consider actual knowledge of orders - Assessing officer's order treated as show cause notice to enable petitioner to file objections.
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