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 found that the first respondent violated the principles of natural justice by passing the impugned order without granting the petitioner the mandatory third personal hearing as required under the relevant provisions. The petitioner had submitted a reply and requested an opportunity for a third hearing and to produce records, which was not afforded. Consequently, the HC set aside the impugned order and remitted the matter to the first respondent with a direction to provide the petitioner a personal hearing on 24-12-2024. The first respondent is to consider the petitioner's submissions and documents and pass a reasoned order on merits in accordance with law. The petition was disposed of accordingly.
The HC found that the first respondent violated the principles of natural justice by passing the impugned order without granting the petitioner the mandatory third personal hearing as required under the relevant provisions. The petitioner had submitted a reply and requested an opportunity for a third hearing and to produce records, which was not afforded. Consequently, the HC set aside the impugned order and remitted the matter to the first respondent with a direction to provide the petitioner a personal hearing on 24-12-2024. The first respondent is to consider the petitioner's submissions and documents and pass a reasoned order on merits in accordance with law. The petition was disposed of accordingly.
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