Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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The HC set aside the impugned rectification order under Section 161 of the CGST/DGST Act, finding it to be cryptic, non-speaking, and issued without affording the petitioner a hearing, thereby violating principles of natural justice. Although the Show Cause Notice and demand order were reasoned and a detailed reply was filed, the rectification order merely dismissed the application as "unsatisfactory" without reasons. The matter was remanded to the Adjudicating Authority for a de novo consideration of the rectification application, ensuring the petitioner is granted an opportunity for a proper hearing. The petition was disposed of accordingly.
The HC set aside the impugned rectification order under Section 161 of the CGST/DGST Act, finding it to be cryptic, non-speaking, and issued without affording the petitioner a hearing, thereby violating principles of natural justice. Although the Show Cause Notice and demand order were reasoned and a detailed reply was filed, the rectification order merely dismissed the application as "unsatisfactory" without reasons. The matter was remanded to the Adjudicating Authority for a de novo consideration of the rectification application, ensuring the petitioner is granted an opportunity for a proper hearing. The petition was disposed of accordingly.
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