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...
Service of a show cause notice must be proved before ex parte adjudication can stand; where the record did not establish service on the assessee, the SC held that the order violated natural justice and set it aside on that limited ground, granting liberty to file a reply and permitting fresh adjudication. The Court, however, rejected the challenge that the notice was vague or issued without application of mind, holding that objection to be without merit and closed for the fresh proceedings. Only the reply to the notice, and any jurisdictional plea open on the record, could be considered by the assessing officer on remand.
Service of a show cause notice must be proved before ex parte adjudication can stand; where the record did not establish service on the assessee, the SC held that the order violated natural justice and set it aside on that limited ground, granting liberty to file a reply and permitting fresh adjudication. The Court, however, rejected the challenge that the notice was vague or issued without application of mind, holding that objection to be without merit and closed for the fresh proceedings. Only the reply to the notice, and any jurisdictional plea open on the record, could be considered by the assessing officer on remand.
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