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 quashed assessment order for 2018-19 due to violation of natural justice principles under Section 169. Authority failed to serve proper notice seeking explanation regarding alleged defects. Following precedent established in prior cases, Court affirmed mandatory requirement of notice delivery either in person, registered post, or registered email. Only upon impracticability of these methods can alternative publication through portal/newspaper be considered. Assessment order converted to show cause notice, allowing petitioner opportunity to respond. Decision upholds fundamental right to be heard before adverse action, reinforcing procedural safeguards in tax assessment proceedings.
HC quashed assessment order for 2018-19 due to violation of natural justice principles under Section 169. Authority failed to serve proper notice seeking explanation regarding alleged defects. Following precedent established in prior cases, Court affirmed mandatory requirement of notice delivery either in person, registered post, or registered email. Only upon impracticability of these methods can alternative publication through portal/newspaper be considered. Assessment order converted to show cause notice, allowing petitioner opportunity to respond. Decision upholds fundamental right to be heard before adverse action, reinforcing procedural safeguards in tax assessment proceedings.
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