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...
Failure to consider a taxpayer's reply to the pre-show cause intimation and supporting documents vitiated the subsequent DRC-01 show cause notice. The HC noted the admitted position that the objections filed against the DRC-01A notice were not examined before issuance of the notice denying input tax credit. In light of the State's statement that the materials would be considered afresh, the Court quashed the impugned notice and directed the competent authority to reconsider the objections and documents and pass a fresh speaking and reasoned order in accordance with law within the stipulated time.
Failure to consider a taxpayer's reply to the pre-show cause intimation and supporting documents vitiated the subsequent DRC-01 show cause notice. The HC noted the admitted position that the objections filed against the DRC-01A notice were not examined before issuance of the notice denying input tax credit. In light of the State's statement that the materials would be considered afresh, the Court quashed the impugned notice and directed the competent authority to reconsider the objections and documents and pass a fresh speaking and reasoned order in accordance with law within the stipulated time.
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