Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Construction of separate villas for individual purchasers, even within a gated layout with common amenities, did not amount to construction of a residential complex for service tax purposes. The Tribunal treated separately identified plots, individual approvals, and contracts with each buyer as independent constructions rather than a single building or buildings with more than twelve residential units. Common project identity and shared facilities were held insufficient to enlarge the taxable definition. The demand was therefore unsustainable, and the related interest and penalties also failed; the VCES declaration did not change that result.
Construction of separate villas for individual purchasers, even within a gated layout with common amenities, did not amount to construction of a residential complex for service tax purposes. The Tribunal treated separately identified plots, individual approvals, and contracts with each buyer as independent constructions rather than a single building or buildings with more than twelve residential units. Common project identity and shared facilities were held insufficient to enlarge the taxable definition. The demand was therefore unsustainable, and the related interest and penalties also failed; the VCES declaration did not change that result.
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