Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4814 
Join Channel 
