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...
The HC set aside the impugned order imposing the penalty, noting that although the petitioner was represented at the personal hearing and lost the right of appeal due to delay, the petitioner must be afforded one final opportunity to present their case before the authority. The petitioner is directed to communicate a certified copy of the HC order to the authority by 30 December 2024; failure to do so will result in automatic restoration of the original order. Upon receipt, the authority shall schedule a hearing to allow the petitioner a last chance to be heard and thereafter pass a fresh adjudicatory order. The petition is disposed of accordingly.
The HC set aside the impugned order imposing the penalty, noting that although the petitioner was represented at the personal hearing and lost the right of appeal due to delay, the petitioner must be afforded one final opportunity to present their case before the authority. The petitioner is directed to communicate a certified copy of the HC order to the authority by 30 December 2024; failure to do so will result in automatic restoration of the original order. Upon receipt, the authority shall schedule a hearing to allow the petitioner a last chance to be heard and thereafter pass a fresh adjudicatory order. The petition is disposed of accordingly.
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