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 set aside the impugned Order-in-Original due to procedural irregularities that violated principles of natural justice. The order had incorrectly proceeded on the premise that the petitioner had not filed any reply to the Show Cause Notices, when in fact a response had been submitted. This factual error constituted a fundamental breach of procedural fairness, as the adjudicating authority failed to consider the petitioner's submissions before reaching its determination. The writ petition was accordingly allowed, invalidating the original order.
The HC set aside the impugned Order-in-Original due to procedural irregularities that violated principles of natural justice. The order had incorrectly proceeded on the premise that the petitioner had not filed any reply to the Show Cause Notices, when in fact a response had been submitted. This factual error constituted a fundamental breach of procedural fairness, as the adjudicating authority failed to consider the petitioner's submissions before reaching its determination. The writ petition was accordingly allowed, invalidating the original order.
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