Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
The HC held that the Assessment Order issued under section 143(3) read with section 144B and the Demand Notice under section 156 were invalid due to violation of the principles of natural justice. The petitioner's specific request for a personal hearing via video conferencing was denied, resulting in a breach of the audi alteram partem rule. The court emphasized that a fair hearing necessitates an opportunity to be heard and a proper chance to defend the case, which was not afforded. Consequently, the impugned orders were quashed and set aside, ruling in favor of the assessee.
The HC held that the Assessment Order issued under section 143(3) read with section 144B and the Demand Notice under section 156 were invalid due to violation of the principles of natural justice. The petitioner's specific request for a personal hearing via video conferencing was denied, resulting in a breach of the audi alteram partem rule. The court emphasized that a fair hearing necessitates an opportunity to be heard and a proper chance to defend the case, which was not afforded. Consequently, the impugned orders were quashed and set aside, ruling in favor of the assessee.
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