Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
Construction for educational institutions and public welfare projects was treated as non-commercial: works for a charitable medical college, police housing and allied welfare facilities did not become taxable merely because fees were collected, incidental revenue arose, or a small shopping or canteen component existed. An accepted VCES declaration could not be reopened as "substantially false" merely because the Department later took a different valuation or interpretational view, so finality attached to the declaration. On limitation and penalty, minor reconciliation differences between the profit and loss account and ST-3 returns, together with payment before notice and absence of suppression, defeated extended limitation and consequential penalties; only the admitted balance manpower-supply liability survived with interest, subject to limitation.
Construction for educational institutions and public welfare projects was treated as non-commercial: works for a charitable medical college, police housing and allied welfare facilities did not become taxable merely because fees were collected, incidental revenue arose, or a small shopping or canteen component existed. An accepted VCES declaration could not be reopened as "substantially false" merely because the Department later took a different valuation or interpretational view, so finality attached to the declaration. On limitation and penalty, minor reconciliation differences between the profit and loss account and ST-3 returns, together with payment before notice and absence of suppression, defeated extended limitation and consequential penalties; only the admitted balance manpower-supply liability survived with interest, subject to limitation.
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