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...
Where registration had already been cancelled, adjudication could continue only on physical service of the show cause notice because the taxpayer could not be expected to access the Common Portal; service merely by electronic upload was therefore inadequate. The absence of physical notice caused a substantial breach of natural justice and denied an effective opportunity to file objections and be heard. The HC accordingly set aside the adjudication order and remitted the matter for fresh adjudication after physical service of notice, supply of relied-upon documents, and grant of due hearing.
Where registration had already been cancelled, adjudication could continue only on physical service of the show cause notice because the taxpayer could not be expected to access the Common Portal; service merely by electronic upload was therefore inadequate. The absence of physical notice caused a substantial breach of natural justice and denied an effective opportunity to file objections and be heard. The HC accordingly set aside the adjudication order and remitted the matter for fresh adjudication after physical service of notice, supply of relied-upon documents, and grant of due hearing.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4819 
Join Channel 
