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...
Freight forwarding on a principal-to-principal basis was treated as an independent transportation arrangement, not a mere intermediary or support activity. The Tribunal accepted that where the forwarder negotiates freight with carriers and customers, procures cargo space on its own account, and bears the legal responsibility and risks of transportation, the amounts recovered from customers for ocean freight and air freight cannot form part of the assessable value for business support service. On that basis, the service tax demand on those freight recoveries was held unsustainable and the impugned order was set aside.
Freight forwarding on a principal-to-principal basis was treated as an independent transportation arrangement, not a mere intermediary or support activity. The Tribunal accepted that where the forwarder negotiates freight with carriers and customers, procures cargo space on its own account, and bears the legal responsibility and risks of transportation, the amounts recovered from customers for ocean freight and air freight cannot form part of the assessable value for business support service. On that basis, the service tax demand on those freight recoveries was held unsustainable and the impugned order was set aside.
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