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...
Outbound tour services conducted wholly outside India were held not liable to service tax under the tour operator service levy because Chapter V of the Finance Act operated only within its territorial scope. On a harmonious reading of sections 64, 65 and 66, journeys that began and ended outside India, and were consumed abroad, fell outside the taxable service definition. The 2004 budget instructions were treated as enlarging the modes of transport for package tours, not as extending the levy to tours performed wholly abroad. The tax demand was set aside, and the related interest and penalties failed as consequential.
Outbound tour services conducted wholly outside India were held not liable to service tax under the tour operator service levy because Chapter V of the Finance Act operated only within its territorial scope. On a harmonious reading of sections 64, 65 and 66, journeys that began and ended outside India, and were consumed abroad, fell outside the taxable service definition. The 2004 budget instructions were treated as enlarging the modes of transport for package tours, not as extending the levy to tours performed wholly abroad. The tax demand was set aside, and the related interest and penalties failed as consequential.
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