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...
The HC allowed the petitioner's challenge to SCN and consequent order dated 31st March 2023, finding violation of natural justice principles due to inadequate opportunity of hearing. The court held that proper hearing rights were denied and remanded the matter to the Adjudicating Authority. The impugned order was set aside. The petitioner was granted extension until 15th July 2025 to file additional reply to SCN, after which the Adjudicating Authority must issue personal hearing notice. The petition was disposed of with directions for fresh adjudication ensuring compliance with natural justice requirements.
The HC allowed the petitioner's challenge to SCN and consequent order dated 31st March 2023, finding violation of natural justice principles due to inadequate opportunity of hearing. The court held that proper hearing rights were denied and remanded the matter to the Adjudicating Authority. The impugned order was set aside. The petitioner was granted extension until 15th July 2025 to file additional reply to SCN, after which the Adjudicating Authority must issue personal hearing notice. The petition was disposed of with directions for fresh adjudication ensuring compliance with natural justice requirements.
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