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 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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