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 rectification application was improperly processed due to violation of principles of natural justice by denying the petitioner an opportunity of hearing. Relying on prior judicial precedent, the court set aside the original order dated 28th February, 2025 and directed that the rectification application be reconsidered after providing a proper hearing to the petitioner in accordance with established legal principles. The petition was consequently disposed of with instructions for procedural compliance.
HC held that the rectification application was improperly processed due to violation of principles of natural justice by denying the petitioner an opportunity of hearing. Relying on prior judicial precedent, the court set aside the original order dated 28th February, 2025 and directed that the rectification application be reconsidered after providing a proper hearing to the petitioner in accordance with established legal principles. The petition was consequently disposed of with instructions for procedural compliance.
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