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...
Under Section 75(4), a personal hearing is required on demand; because the taxpayer did not file a reply to the show-cause notice and never sought a hearing, the HC held there was no breach of natural justice. The Court also held that the summary GST demand order issued in DRC-07 under Section 73 was appealable under the statute, so objections on merits or technical grounds should have been raised before the appellate authority. Having failed to participate in the proceedings and let the appeal period lapse, the taxpayer could not invoke writ jurisdiction. The writ petition was dismissed.
Under Section 75(4), a personal hearing is required on demand; because the taxpayer did not file a reply to the show-cause notice and never sought a hearing, the HC held there was no breach of natural justice. The Court also held that the summary GST demand order issued in DRC-07 under Section 73 was appealable under the statute, so objections on merits or technical grounds should have been raised before the appellate authority. Having failed to participate in the proceedings and let the appeal period lapse, the taxpayer could not invoke writ jurisdiction. The writ petition was dismissed.
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