Tax exemption for regulatory authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and return filing...
Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Indivisible turnkey ATM contracts comprising supply, installation, testing and commissioning for a single composite consideration cannot be split to levy service tax on a notional commissioning or installation component where the Finance Act, 1994 provided no charging or valuation mechanism for that segregation. The discussion applies the principle that pre-existing service-tax entries covered service contracts simpliciter and did not permit vivisection of composite contracts before the introduction of works contract service. Consequently, attributing part of the composite consideration to commissioning or installation lacked statutory authority, rendering the related service-tax demand unsustainable.
Indivisible turnkey ATM contracts comprising supply, installation, testing and commissioning for a single composite consideration cannot be split to levy service tax on a notional commissioning or installation component where the Finance Act, 1994 provided no charging or valuation mechanism for that segregation. The discussion applies the principle that pre-existing service-tax entries covered service contracts simpliciter and did not permit vivisection of composite contracts before the introduction of works contract service. Consequently, attributing part of the composite consideration to commissioning or installation lacked statutory authority, rendering the related service-tax demand unsustainable.
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