Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
The HC set aside an impugned appellate order dated 28 September 2024 for breach of natural justice, holding that the appellant was not afforded an opportunity to be heard and was unable to adduce documents or have pleaded grounds of appeal considered. The HC remanded the matter to the State-Tax Additional Commissioner (Appeal), Santhal Pargana Division, Dumka, directing a de novo adjudication after affording the parties a full and fair hearing and considering materials produced. The HC emphasized that quasi-judicial authorities must observe principles of fairness and provide hearing where decisions may cause civil consequences. Petition disposed of by remand.
The HC set aside an impugned appellate order dated 28 September 2024 for breach of natural justice, holding that the appellant was not afforded an opportunity to be heard and was unable to adduce documents or have pleaded grounds of appeal considered. The HC remanded the matter to the State-Tax Additional Commissioner (Appeal), Santhal Pargana Division, Dumka, directing a de novo adjudication after affording the parties a full and fair hearing and considering materials produced. The HC emphasized that quasi-judicial authorities must observe principles of fairness and provide hearing where decisions may cause civil consequences. Petition disposed of by remand.
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