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...
HC determined that the undated demand order was procedurally defective under Section 75(6), lacking substantive reasoning beyond referencing a show cause notice. The court remanded the matter to the respondent, directing them to provide the petitioner an opportunity to respond to the original show cause notice within four weeks. Following the petitioner's response, the respondent must conduct a hearing and issue a legally compliant order. The petition was allowed through judicial remand, requiring procedural rectification of the original administrative action.
HC determined that the undated demand order was procedurally defective under Section 75(6), lacking substantive reasoning beyond referencing a show cause notice. The court remanded the matter to the respondent, directing them to provide the petitioner an opportunity to respond to the original show cause notice within four weeks. Following the petitioner's response, the respondent must conduct a hearing and issue a legally compliant order. The petition was allowed through judicial remand, requiring procedural rectification of the original administrative action.
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