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 allowed the petition and set aside the assessment order dated 29.01.2025 and its summary, holding the respondent's proceedings vitiated by breach of natural justice and excessive delay. The court found the petitioner reasonably unaware of portal-notices uploaded after approximately 1½ years and held the statutory/administrative timeline for proceedings under section 73 required prompt adjudication; the belated confirmation of the show-cause proceedings and absence of effective communication rendered the assessment voidable. The matter is remitted to the first respondent for fresh consideration in accordance with law; the petition is allowed by way of remand.
The HC allowed the petition and set aside the assessment order dated 29.01.2025 and its summary, holding the respondent's proceedings vitiated by breach of natural justice and excessive delay. The court found the petitioner reasonably unaware of portal-notices uploaded after approximately 1½ years and held the statutory/administrative timeline for proceedings under section 73 required prompt adjudication; the belated confirmation of the show-cause proceedings and absence of effective communication rendered the assessment voidable. The matter is remitted to the first respondent for fresh consideration in accordance with law; the petition is allowed by way of remand.
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