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 nullified best judgment assessment under GST due to procedural irregularities. The court found the assessment order invalid as the tax authority failed to issue mandatory notice under Section 46 and did not provide an opportunity of hearing, thereby violating principles of natural justice. The assessment order lacked substantive material and reasoning required for Section 62 invocation. Consequently, both assessment orders dated 27.08.2019 and 29.01.2025 were quashed, emphasizing the necessity of procedural compliance in tax assessment proceedings.
HC nullified best judgment assessment under GST due to procedural irregularities. The court found the assessment order invalid as the tax authority failed to issue mandatory notice under Section 46 and did not provide an opportunity of hearing, thereby violating principles of natural justice. The assessment order lacked substantive material and reasoning required for Section 62 invocation. Consequently, both assessment orders dated 27.08.2019 and 29.01.2025 were quashed, emphasizing the necessity of procedural compliance in tax assessment proceedings.
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