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...
HC allowed the writ petition and quashed the show cause notice and consequential orders issued under Section 74 of the Act. The court held that initiation of proceedings against a deceased proprietor was void ab initio where death had been notified to authorities, and that proceedings cannot validly be instituted against a deceased person, the estate or legal heirs absent proper service on or substitution of the legal representative. The HC found the SCN and subsequent ex parte order unsustainable for failure to proceed against the legal representative/heirs in accordance with law. The impugned SCN and ex parte order were set aside and the petition challenging those proceedings was allowed.
HC allowed the writ petition and quashed the show cause notice and consequential orders issued under Section 74 of the Act. The court held that initiation of proceedings against a deceased proprietor was void ab initio where death had been notified to authorities, and that proceedings cannot validly be instituted against a deceased person, the estate or legal heirs absent proper service on or substitution of the legal representative. The HC found the SCN and subsequent ex parte order unsustainable for failure to proceed against the legal representative/heirs in accordance with law. The impugned SCN and ex parte order were set aside and the petition challenging those proceedings was allowed.
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