Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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Wall rent paid for sites used to display advertisements was held includible in the taxable value of advertising agency service because it was an intrinsic and inseparable part of the service, and the assessee failed to establish a valid pure agent arrangement or direct contractual link between clients and wall owners. By contrast, the value of printed flex material supplied through a separately registered concern, separately invoiced and taxed as goods, was held not includible under the service tax valuation rules or Notification No. 12/2003-ST. The extended limitation period was rejected because suppression or wilful misstatement was not proved in an audit-based notice, and penalties were deleted as the dispute was interpretational.
Wall rent paid for sites used to display advertisements was held includible in the taxable value of advertising agency service because it was an intrinsic and inseparable part of the service, and the assessee failed to establish a valid pure agent arrangement or direct contractual link between clients and wall owners. By contrast, the value of printed flex material supplied through a separately registered concern, separately invoiced and taxed as goods, was held not includible under the service tax valuation rules or Notification No. 12/2003-ST. The extended limitation period was rejected because suppression or wilful misstatement was not proved in an audit-based notice, and penalties were deleted as the dispute was interpretational.
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