SEZ-unit profit deduction covers voluntary transfer-pricing adjustments, while exempt-income costs, foreign-exchange loss and ITeS comparables are exa...
Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
The HC held that the impugned assessment order violated principles of natural justice and suffered from non-application of mind. Despite the petitioner filing multiple replies on 28.10.2023, 21.11.2023, 29.11.2023, and 18.12.2023 to the Show Cause Notice, the authority failed to consider these submissions or even reference them in the final order. Additionally, no opportunity for personal hearing was provided to the petitioner before passing the order. The Court determined that this constituted a gross violation of natural justice principles and demonstrated failure to properly consider material evidence on record. The petition was accordingly disposed of in favor of the petitioner.
The HC held that the impugned assessment order violated principles of natural justice and suffered from non-application of mind. Despite the petitioner filing multiple replies on 28.10.2023, 21.11.2023, 29.11.2023, and 18.12.2023 to the Show Cause Notice, the authority failed to consider these submissions or even reference them in the final order. Additionally, no opportunity for personal hearing was provided to the petitioner before passing the order. The Court determined that this constituted a gross violation of natural justice principles and demonstrated failure to properly consider material evidence on record. The petition was accordingly disposed of in favor of the petitioner.
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TaxTMI 
TaxTMI 
of 4897 
