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 held that the SCN was improperly served by uploading it to the Additional notices tab, violating principles of natural justice. Following precedent, the SCN was set aside. The Adjudicating Authority must reissue the SCN and pass a fresh adjudication order, which remains subject to potential Supreme Court review of the underlying notification. The demand order dated 27th December 2023 was consequently nullified due to procedural irregularities in SCN service, effectively rendering the original tax demand invalid.
HC held that the SCN was improperly served by uploading it to the Additional notices tab, violating principles of natural justice. Following precedent, the SCN was set aside. The Adjudicating Authority must reissue the SCN and pass a fresh adjudication order, which remains subject to potential Supreme Court review of the underlying notification. The demand order dated 27th December 2023 was consequently nullified due to procedural irregularities in SCN service, effectively rendering the original tax demand invalid.
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