Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Lease of the closed sugar factory premises was treated as renting of factory premises, not mere leasing of land, so service tax liability was upheld on merits and PSU status did not confer any exemption. However, the Tribunal found no suppression with intent to evade because the levy on renting of immovable property was under judicial uncertainty, no tax had been collected from lessees, and no deliberate evasion was shown. As the notice was issued before insertion of section 73(2A) and retrospective operation was not established, the extended period could not be invoked and the normal-period demand also fell. The entire demand was set aside as time-barred.
Lease of the closed sugar factory premises was treated as renting of factory premises, not mere leasing of land, so service tax liability was upheld on merits and PSU status did not confer any exemption. However, the Tribunal found no suppression with intent to evade because the levy on renting of immovable property was under judicial uncertainty, no tax had been collected from lessees, and no deliberate evasion was shown. As the notice was issued before insertion of section 73(2A) and retrospective operation was not established, the extended period could not be invoked and the normal-period demand also fell. The entire demand was set aside as time-barred.
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