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 set aside the impugned adjudication and remanded the matter to the concerned Adjudicating Authority for fresh adjudication, observing a breach of natural justice. The court found that the show-cause notice was uploaded only to the portal's "Additional Notices" tab and the Petitioner had not availed any personal hearing or filed a reply, resulting in denial of an effective opportunity to be heard. In light of the portal's asymmetric visibility and the Department's concession regarding portal operation, the HC directed the authority to afford the Petitioner a proper opportunity of hearing and to decide the matter afresh in accordance with law. Petition disposed.
The HC set aside the impugned adjudication and remanded the matter to the concerned Adjudicating Authority for fresh adjudication, observing a breach of natural justice. The court found that the show-cause notice was uploaded only to the portal's "Additional Notices" tab and the Petitioner had not availed any personal hearing or filed a reply, resulting in denial of an effective opportunity to be heard. In light of the portal's asymmetric visibility and the Department's concession regarding portal operation, the HC directed the authority to afford the Petitioner a proper opportunity of hearing and to decide the matter afresh in accordance with law. Petition disposed.
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