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 principles of natural justice were violated when petitioner was denied personal hearing despite sufficient time between response filing and order issuance. The authority failed to provide opportunity under Section 75(4), which mandates hearing before adverse order. Given potential substantive arguments in petitioner's response, the procedural defect was material. The impugned order was consequently set aside, with petition allowed, emphasizing the critical importance of procedural fairness in administrative proceedings.
HC held that principles of natural justice were violated when petitioner was denied personal hearing despite sufficient time between response filing and order issuance. The authority failed to provide opportunity under Section 75(4), which mandates hearing before adverse order. Given potential substantive arguments in petitioner's response, the procedural defect was material. The impugned order was consequently set aside, with petition allowed, emphasizing the critical importance of procedural fairness in administrative proceedings.
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