Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
The HC quashed and set aside the Appellate Order, the dismissal of the revocation application and the order of cancellation of registration, finding a breach of the principles of natural justice in that no hearing was afforded and the notices and orders lacked reasons. The matter is remitted with liberty to R2 to issue a fresh show-cause notice specifying particulars and reasons, to afford P a reasonable opportunity of hearing, and thereafter to pass a reasoned speaking order on the merits. The petition is allowed solely on natural justice grounds, following the Court's analogous reasoning in the coordinate bench authority.
The HC quashed and set aside the Appellate Order, the dismissal of the revocation application and the order of cancellation of registration, finding a breach of the principles of natural justice in that no hearing was afforded and the notices and orders lacked reasons. The matter is remitted with liberty to R2 to issue a fresh show-cause notice specifying particulars and reasons, to afford P a reasonable opportunity of hearing, and thereafter to pass a reasoned speaking order on the merits. The petition is allowed solely on natural justice grounds, following the Court's analogous reasoning in the coordinate bench authority.
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