Business deductions and transfer pricing issues: tribunal treatment of software write-offs, donation receipts, warranty provisions, and related expens...
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HC upheld the original ruling, finding no violation of natural justice principles in the administrative proceedings. The appellant had received proper notice (Ext.P2) and submitted a response (Ext.P4), including a request for extension to provide additional clarifications. The procedural timeline allowed for reply submission by 27.12.2024 with personal hearing scheduled for 06.01.2025. The court determined that adequate opportunity for representation was provided, satisfying natural justice requirements. The appellant's contention regarding denial of hearing opportunity was rejected, and the appeal was dismissed, affirming the learned Single Judge's determination.
HC upheld the original ruling, finding no violation of natural justice principles in the administrative proceedings. The appellant had received proper notice (Ext.P2) and submitted a response (Ext.P4), including a request for extension to provide additional clarifications. The procedural timeline allowed for reply submission by 27.12.2024 with personal hearing scheduled for 06.01.2025. The court determined that adequate opportunity for representation was provided, satisfying natural justice requirements. The appellant's contention regarding denial of hearing opportunity was rejected, and the appeal was dismissed, affirming the learned Single Judge's determination.
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