Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
Services performed and consumed outside India were held not taxable in India under reverse charge, because the overseas inspection and processing activities related to exported goods and fell outside the import-of-service rule. The Tribunal also found the classification in the impugned order unsustainable, since the same services were not given a clear and consistent sub-clause under Business Auxiliary Service. Best judgment computation based on doubled historical figures was rejected as arbitrary where there was no evidence of later payments. The extended period of limitation was also denied, as prior audits and filed returns undermined any allegation of suppression or intent to evade.
Services performed and consumed outside India were held not taxable in India under reverse charge, because the overseas inspection and processing activities related to exported goods and fell outside the import-of-service rule. The Tribunal also found the classification in the impugned order unsustainable, since the same services were not given a clear and consistent sub-clause under Business Auxiliary Service. Best judgment computation based on doubled historical figures was rejected as arbitrary where there was no evidence of later payments. The extended period of limitation was also denied, as prior audits and filed returns undermined any allegation of suppression or intent to evade.
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