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...
Requirement that final tax demand be confined to the amount proposed in the show cause notice under Section 75(7) is reiterated; where an adjudication confirms a demand exceeding the notice the order is contrary to the statutory limitation and must be set aside. The court remitted the matter for fresh adjudication, directed the taxpayer to file a reply treating the impugned order as an addendum within thirty days, and ordered the tax authority to pass a fresh final order expeditiously, with recovery measures available if the taxpayer fails to comply after due notice.
Requirement that final tax demand be confined to the amount proposed in the show cause notice under Section 75(7) is reiterated; where an adjudication confirms a demand exceeding the notice the order is contrary to the statutory limitation and must be set aside. The court remitted the matter for fresh adjudication, directed the taxpayer to file a reply treating the impugned order as an addendum within thirty days, and ordered the tax authority to pass a fresh final order expeditiously, with recovery measures available if the taxpayer fails to comply after due notice.
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