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 allowed the petition challenging the SCN issued beyond prescribed limitation period. The court found procedural irregularities in the notice, specifically the lack of opportunity for hearing, which violated principles of natural justice. The impugned order was set aside and remanded back to the Adjudicating Authority. The Petitioner was granted permission to file a reply by 15th July, 2025, with a mandatory personal hearing to be provided thereafter. The challenge to the extension of limitation through Notification 56/2023 remains pending before the Supreme Court, which influenced the HC's decision to provide procedural fairness.
HC allowed the petition challenging the SCN issued beyond prescribed limitation period. The court found procedural irregularities in the notice, specifically the lack of opportunity for hearing, which violated principles of natural justice. The impugned order was set aside and remanded back to the Adjudicating Authority. The Petitioner was granted permission to file a reply by 15th July, 2025, with a mandatory personal hearing to be provided thereafter. The challenge to the extension of limitation through Notification 56/2023 remains pending before the Supreme Court, which influenced the HC's decision to provide procedural fairness.
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