Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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HC found a violation of Section 75(7) where the demand amount (Rs. 59,27,500/-) exceeded the show-cause notice amount (Rs. 28,15,200/-). Despite procedural irregularities in hearing scheduling, the court primarily focused on the statutory non-compliance. The impugned order was set aside, and the matter was remanded to the respondent to provide proper opportunity of hearing and issue a fresh order in accordance with legal provisions, thereby allowing the petition and ensuring procedural fairness.
HC found a violation of Section 75(7) where the demand amount (Rs. 59,27,500/-) exceeded the show-cause notice amount (Rs. 28,15,200/-). Despite procedural irregularities in hearing scheduling, the court primarily focused on the statutory non-compliance. The impugned order was set aside, and the matter was remanded to the respondent to provide proper opportunity of hearing and issue a fresh order in accordance with legal provisions, thereby allowing the petition and ensuring procedural fairness.
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