Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
Strict construction of exemption notifications barred astronomy coaching from the recreational activities exemption in Entry 8 of Notification No. 25/2012-ST, because the word "culture" was read in context with arts and sports under noscitur a sociis and could not be stretched to scientific training. The Tribunal therefore upheld denial of exemption and sustained the demand on merits. It also held that non-registration, non-filing of returns, and long-term commercial conduct amounted to suppression of material facts, so the extended period, interest, and penalty were justified. Cum-tax benefit under section 67(2) was allowed, but only for limited recomputation of the demand.
Strict construction of exemption notifications barred astronomy coaching from the recreational activities exemption in Entry 8 of Notification No. 25/2012-ST, because the word "culture" was read in context with arts and sports under noscitur a sociis and could not be stretched to scientific training. The Tribunal therefore upheld denial of exemption and sustained the demand on merits. It also held that non-registration, non-filing of returns, and long-term commercial conduct amounted to suppression of material facts, so the extended period, interest, and penalty were justified. Cum-tax benefit under section 67(2) was allowed, but only for limited recomputation of the demand.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4790
Join Channel
TaxTMI 
