Defined public benefit can retain charitable character; registration renewal requires examining genuine activities and legal compliance, not surplus a...
Capital reduction is distinct from share buy-back, preventing buy-back tax; restructuring interest and related business deductions also survive scruti...
Transfer pricing and tax deductions upheld on established principles, while employee contributions and warranty provisions returned for fresh examinat...
Captive transfer pricing relies on industrial consumer tariffs, while genuine quotations can benchmark effluent treatment transfers under the Other Me...
Specific tariff classification for ophthalmic instruments and extended limitation principles determine the treatment of duty demands, confiscation, an...
Composite EPC/turnkey public utility construction contracts for Government agencies were held not to be Consulting Engineer's service because the agreements showed complete construction, procurement, labour, commissioning, quality and maintenance obligations, with the fee representing only the contractor's profit margin. The Revenue could not vivisect the contract and tax only the fee component under that head, so the demand failed on classification. The extended period was also inapplicable because the projects were treated as exempt public utility works, the assessee acted under bona fide belief, and there was no specific evidence of wilful suppression or intent to evade.
Composite EPC/turnkey public utility construction contracts for Government agencies were held not to be Consulting Engineer's service because the agreements showed complete construction, procurement, labour, commissioning, quality and maintenance obligations, with the fee representing only the contractor's profit margin. The Revenue could not vivisect the contract and tax only the fee component under that head, so the demand failed on classification. The extended period was also inapplicable because the projects were treated as exempt public utility works, the assessee acted under bona fide belief, and there was no specific evidence of wilful suppression or intent to evade.
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