Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
HC set aside demand orders dated 23rd April, 2024 and 5th December, 2023 due to violation of principles of natural justice, specifically the failure to properly notify the Petitioner about show cause notices (SCN). The Court directed the Petitioner to file replies to SCNs within thirty days, mandated that hearing notices be both uploaded and e-mailed, and instructed the Department to adjudicate the show cause notices in accordance with legal procedures. The case was disposed of with specific procedural guidelines ensuring proper communication and opportunity for the Petitioner to present its case.
HC set aside demand orders dated 23rd April, 2024 and 5th December, 2023 due to violation of principles of natural justice, specifically the failure to properly notify the Petitioner about show cause notices (SCN). The Court directed the Petitioner to file replies to SCNs within thirty days, mandated that hearing notices be both uploaded and e-mailed, and instructed the Department to adjudicate the show cause notices in accordance with legal procedures. The case was disposed of with specific procedural guidelines ensuring proper communication and opportunity for the Petitioner to present its case.
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