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...
Petition challenges validity of an assessment completed under faceless assessment where the taxpayer was prevented by the portal from filing a reply and from obtaining a personal hearing; an online grievance remained unredressed. The court found these procedural deprivations breached the principles of natural justice, declined to consider the substantive merits, and held the assessment and consequential demand invalid for want of opportunity to be heard. The operative effect directs reopening of assessment proceedings, permitting filing of the reply and affording an opportunity of hearing before any fresh orders are passed.
Petition challenges validity of an assessment completed under faceless assessment where the taxpayer was prevented by the portal from filing a reply and from obtaining a personal hearing; an online grievance remained unredressed. The court found these procedural deprivations breached the principles of natural justice, declined to consider the substantive merits, and held the assessment and consequential demand invalid for want of opportunity to be heard. The operative effect directs reopening of assessment proceedings, permitting filing of the reply and affording an opportunity of hearing before any fresh orders are passed.
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