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 held that issuance of a show-cause notice with one day's hearing notice and post-hearing/email communications violated the principles of natural justice. The writ petition was disposed of while declining to strike down the SCN on jurisdictional grounds. The Petitioner is directed to file a substantive reply to the SCN within 30 days (deadline: 30 September 2025). The Department shall grant the Petitioner a personal hearing, and the Adjudicating Authority must thereafter pass a detailed, reasoned order. No other relief granted; procedural non-compliance remedied by affording adequate time and hearing before further adjudication.
The HC held that issuance of a show-cause notice with one day's hearing notice and post-hearing/email communications violated the principles of natural justice. The writ petition was disposed of while declining to strike down the SCN on jurisdictional grounds. The Petitioner is directed to file a substantive reply to the SCN within 30 days (deadline: 30 September 2025). The Department shall grant the Petitioner a personal hearing, and the Adjudicating Authority must thereafter pass a detailed, reasoned order. No other relief granted; procedural non-compliance remedied by affording adequate time and hearing before further adjudication.
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