MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
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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