Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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A personal hearing fixed before the expiry of time allowed for filing a reply to the show cause notice was not an effective opportunity, and the procedure adopted breached principles of natural justice. The assessment order passed under Section 73(9) was therefore unsustainable and quashed by the HC. The matter was remitted to the Assessing Officer to proceed again from the show cause notice stage, with liberty to the taxpayer to file a reply and a fresh personal hearing to be fixed thereafter.
A personal hearing fixed before the expiry of time allowed for filing a reply to the show cause notice was not an effective opportunity, and the procedure adopted breached principles of natural justice. The assessment order passed under Section 73(9) was therefore unsustainable and quashed by the HC. The matter was remitted to the Assessing Officer to proceed again from the show cause notice stage, with liberty to the taxpayer to file a reply and a fresh personal hearing to be fixed thereafter.
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