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 order dated 30.06.2025, holding it to be a non-speaking order that violated principles of natural justice by failing to address the petitioner's explanations and objections. The impugned order is to be treated as a show cause notice; the petitioner may file objections with supporting documents within four weeks of receipt of this order. The first respondent/revenue is directed to issue requisite notice, afford an opportunity of hearing, reconsider the matter, and redo the assessment by passing a speaking order addressing the objections, input tax credit and stock variation issues. The petition is disposed of subject to compliance with these directions.
The HC set aside the impugned order dated 30.06.2025, holding it to be a non-speaking order that violated principles of natural justice by failing to address the petitioner's explanations and objections. The impugned order is to be treated as a show cause notice; the petitioner may file objections with supporting documents within four weeks of receipt of this order. The first respondent/revenue is directed to issue requisite notice, afford an opportunity of hearing, reconsider the matter, and redo the assessment by passing a speaking order addressing the objections, input tax credit and stock variation issues. The petition is disposed of subject to compliance with these directions.
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