Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
High Court held that a mandatory three-month gap between issuance of a CGST show cause notice and passing of the adjudication order is required to secure principles of natural justice and the right to personal hearing; shortening that interval undermines service of the statement of demand, the assessee's self-assessment option and ability to obtain adjournments, and therefore renders orders passed within a shorter period unsustainable. Applying that principle, the court quashed and set aside the show cause notice issued on 15-5-2024 and the adjudication order dated 9-7-2024 as the gap was under three months.
High Court held that a mandatory three-month gap between issuance of a CGST show cause notice and passing of the adjudication order is required to secure principles of natural justice and the right to personal hearing; shortening that interval undermines service of the statement of demand, the assessee's self-assessment option and ability to obtain adjournments, and therefore renders orders passed within a shorter period unsustainable. Applying that principle, the court quashed and set aside the show cause notice issued on 15-5-2024 and the adjudication order dated 9-7-2024 as the gap was under three months.
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