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 ex-parte order violated principles of natural justice by failing to serve show cause notice to the petitioner, thereby denying opportunity of being heard. Strict interpretation of tax statutes mandates procedural compliance, particularly regarding personal hearing requirements. The court emphasized that penal statutes affecting individual rights must be construed narrowly to prevent arbitrary decision-making. Consequently, the impugned order was declared unsustainable, and the petitioner was directed to be afforded a fresh opportunity to present its case before the competent authority.
HC held that ex-parte order violated principles of natural justice by failing to serve show cause notice to the petitioner, thereby denying opportunity of being heard. Strict interpretation of tax statutes mandates procedural compliance, particularly regarding personal hearing requirements. The court emphasized that penal statutes affecting individual rights must be construed narrowly to prevent arbitrary decision-making. Consequently, the impugned order was declared unsustainable, and the petitioner was directed to be afforded a fresh opportunity to present its case before the competent authority.
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