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 due to violation of natural justice principles, specifically non-service of notices and orders that prevented the petitioner from participating in adjudication proceedings. The petitioner demonstrated willingness to pay 25% of the disputed tax amount. The Court allowed the petition with the condition that the petitioner must deposit 25% of the disputed taxes within four weeks from receipt of the order copy. This resolution balances procedural fairness with the petitioner's tax obligations while providing an opportunity for proper adjudication.
The HC set aside the impugned order due to violation of natural justice principles, specifically non-service of notices and orders that prevented the petitioner from participating in adjudication proceedings. The petitioner demonstrated willingness to pay 25% of the disputed tax amount. The Court allowed the petition with the condition that the petitioner must deposit 25% of the disputed taxes within four weeks from receipt of the order copy. This resolution balances procedural fairness with the petitioner's tax obligations while providing an opportunity for proper adjudication.
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