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 set aside the tax notice (N/N. 56/2023) due to procedural irregularities in service of Show Cause Notice (SCN). The court found fundamental violations of natural justice, as the SCN was undated and not properly received by the Petitioner. Following precedential rulings in similar tax dispute cases, the court remanded the matter back to the tax authorities, directing them to provide a fair opportunity for the Petitioner to file a reply and receive a personal hearing. The decision mandates a de novo review of the case, ensuring the Petitioner can present their submissions on merits before any final determination.
HC set aside the tax notice (N/N. 56/2023) due to procedural irregularities in service of Show Cause Notice (SCN). The court found fundamental violations of natural justice, as the SCN was undated and not properly received by the Petitioner. Following precedential rulings in similar tax dispute cases, the court remanded the matter back to the tax authorities, directing them to provide a fair opportunity for the Petitioner to file a reply and receive a personal hearing. The decision mandates a de novo review of the case, ensuring the Petitioner can present their submissions on merits before any final determination.
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