Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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HC held that the SCN issued on 29th September 2023 was not properly brought to the petitioner's notice, violating principles of natural justice. Given the lack of opportunity to be heard and no reply filed, the court remanded the matter back to the concerned Adjudicating Authority. The decision requires the department to ensure proper communication of show cause notices and provide adequate opportunity for the petitioner to respond, effectively setting aside potential proceedings and mandating a fresh review of the case.
HC held that the SCN issued on 29th September 2023 was not properly brought to the petitioner's notice, violating principles of natural justice. Given the lack of opportunity to be heard and no reply filed, the court remanded the matter back to the concerned Adjudicating Authority. The decision requires the department to ensure proper communication of show cause notices and provide adequate opportunity for the petitioner to respond, effectively setting aside potential proceedings and mandating a fresh review of the case.
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