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 dismissed writ petition challenging assessment order under s.143(3) r.w.s. 144B, finding no clear breach of natural justice principles to warrant bypassing alternate remedies. Show-cause notice adequately informed petitioner about unreliable sales figures and proposed assessment methodology. Final assessment order did not materially deviate from notice parameters. Petitioner's conditional request for video conferencing hearing was not mandatory since AO required no clarifications. Court held statutory appeals must be exhausted first as no patent violation of natural justice was established to justify extraordinary writ jurisdiction.
HC dismissed writ petition challenging assessment order under s.143(3) r.w.s. 144B, finding no clear breach of natural justice principles to warrant bypassing alternate remedies. Show-cause notice adequately informed petitioner about unreliable sales figures and proposed assessment methodology. Final assessment order did not materially deviate from notice parameters. Petitioner's conditional request for video conferencing hearing was not mandatory since AO required no clarifications. Court held statutory appeals must be exhausted first as no patent violation of natural justice was established to justify extraordinary writ jurisdiction.
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