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...
The HC held that the order passed under Section 147 read with Section 144B of the I.T. Act was invalid due to non-compliance with natural justice principles. The NFAC granted the petitioner only four days to upload voluminous evidence, contrary to the seven-day period mandated by the Standard Operating Procedure under Section 144B(6)(xi). This insufficient time frame deprived the petitioner of a reasonable opportunity to respond. Consequently, the Court found a manifest violation of procedural fairness and set aside the assessment order. The petitioner's appeal was allowed, emphasizing adherence to prescribed timelines to uphold natural justice in faceless assessments.
The HC held that the order passed under Section 147 read with Section 144B of the I.T. Act was invalid due to non-compliance with natural justice principles. The NFAC granted the petitioner only four days to upload voluminous evidence, contrary to the seven-day period mandated by the Standard Operating Procedure under Section 144B(6)(xi). This insufficient time frame deprived the petitioner of a reasonable opportunity to respond. Consequently, the Court found a manifest violation of procedural fairness and set aside the assessment order. The petitioner's appeal was allowed, emphasizing adherence to prescribed timelines to uphold natural justice in faceless assessments.
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TaxTMI 
TaxTMI 
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