Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
When a tax notice was uploaded only on the GST portal and the recipient did not receive the original, the uploading was held insufficient to afford an effective personal hearing; the issuing officer must explore alternative modes of service (including registered post with acknowledgment) before proceeding ex parte. The impugned assessment was set aside for lack of opportunity of hearing and the matter remanded for fresh consideration, subject to the condition that the taxpayer deposit 25% of the disputed tax within four weeks; the setting aside takes effect from the date of that payment.
When a tax notice was uploaded only on the GST portal and the recipient did not receive the original, the uploading was held insufficient to afford an effective personal hearing; the issuing officer must explore alternative modes of service (including registered post with acknowledgment) before proceeding ex parte. The impugned assessment was set aside for lack of opportunity of hearing and the matter remanded for fresh consideration, subject to the condition that the taxpayer deposit 25% of the disputed tax within four weeks; the setting aside takes effect from the date of that payment.
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