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 dismissed petitioner's challenge to order under Section 73 of WBGST/CGST Act, 2017. Petitioner contended proper officer predetermined outcome by serving Form GST DRC-01A notice before show cause notice, violating natural justice. Court found no irregularity as petitioner received adequate opportunity to respond to show cause before personal hearing was scheduled. Despite petitioner's claim of unawareness due to accountant change, Court noted petitioner continued portal operations and filing returns throughout proceedings. Section 75(4) permits hearing opportunity when adverse decision is contemplated. Petitioner failed to appear for scheduled hearing, thus cannot question the process. No predetermination or natural justice violation established. Petition disposed of without interference to impugned order.
HC dismissed petitioner's challenge to order under Section 73 of WBGST/CGST Act, 2017. Petitioner contended proper officer predetermined outcome by serving Form GST DRC-01A notice before show cause notice, violating natural justice. Court found no irregularity as petitioner received adequate opportunity to respond to show cause before personal hearing was scheduled. Despite petitioner's claim of unawareness due to accountant change, Court noted petitioner continued portal operations and filing returns throughout proceedings. Section 75(4) permits hearing opportunity when adverse decision is contemplated. Petitioner failed to appear for scheduled hearing, thus cannot question the process. No predetermination or natural justice violation established. Petition disposed of without interference to impugned order.
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