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 impugned adjudication orders passed under s.73 of the GST Act violated principles of natural justice by denying personal hearing; in light of the Division Bench's pronouncement that personal hearing must ordinarily be afforded before adverse adjudicatory orders, the Court quashed the orders dated 11.12.2023 and 09.09.2025 as unsustainable. The matter is remitted to the assessing authority for de novo adjudication after affording the petitioner an opportunity of personal hearing. The petition is allowed; any limitation-based objections to earlier dismissal were considered but the lack of hearing rendered the prior orders void, necessitating fresh proceedings.
The HC held that the impugned adjudication orders passed under s.73 of the GST Act violated principles of natural justice by denying personal hearing; in light of the Division Bench's pronouncement that personal hearing must ordinarily be afforded before adverse adjudicatory orders, the Court quashed the orders dated 11.12.2023 and 09.09.2025 as unsustainable. The matter is remitted to the assessing authority for de novo adjudication after affording the petitioner an opportunity of personal hearing. The petition is allowed; any limitation-based objections to earlier dismissal were considered but the lack of hearing rendered the prior orders void, necessitating fresh proceedings.
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