Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
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Transportation and insurance charges recovered for moving goods were not taxable as business support service where the appellant was not acting as a goods transport agency issuing consignment notes; transportation by road by a person other than a GTA remained outside the levy, and the insurance element was treated as bundled with transport. Reverse charge on accounting services supplied to the Ethiopian branch also failed because the services were received and used in Ethiopia, with the branch and Indian office treated as separate permanent establishments. The extended period of limitation was unavailable because the demand rested on disclosed balance-sheet figures, so the related penalty, interest, and remaining penalties also fell.
Transportation and insurance charges recovered for moving goods were not taxable as business support service where the appellant was not acting as a goods transport agency issuing consignment notes; transportation by road by a person other than a GTA remained outside the levy, and the insurance element was treated as bundled with transport. Reverse charge on accounting services supplied to the Ethiopian branch also failed because the services were received and used in Ethiopia, with the branch and Indian office treated as separate permanent establishments. The extended period of limitation was unavailable because the demand rested on disclosed balance-sheet figures, so the related penalty, interest, and remaining penalties also fell.
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