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 the adjudicatory process was vitiated for breach of natural justice because the show-cause notice failed to disclose the materials underpinning the allegation of tax evasion, depriving the petitioner of an opportunity to reply; such procedural infirmity is incurable at appellate stages. Consequently, the adjudicating authority's rectification order dated 16.10.2023 insofar as it confirmed a demand of Rs. 40,37,877/- was set aside and quashed; the appellate authority's order dated 17.02.2025 upholding that finding and the consequent demand notice of 17.02.2025 were likewise set aside and quashed. The writ petition was disposed of.
The HC held that the adjudicatory process was vitiated for breach of natural justice because the show-cause notice failed to disclose the materials underpinning the allegation of tax evasion, depriving the petitioner of an opportunity to reply; such procedural infirmity is incurable at appellate stages. Consequently, the adjudicating authority's rectification order dated 16.10.2023 insofar as it confirmed a demand of Rs. 40,37,877/- was set aside and quashed; the appellate authority's order dated 17.02.2025 upholding that finding and the consequent demand notice of 17.02.2025 were likewise set aside and quashed. The writ petition was disposed of.
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