Unverified Insight Portal Information Cannot Justify Reassessment Without a Verified Taxpayer-Specific Income-Escape Nexus or Demonstrated Application...
Assessing Officer jurisdiction after statutory transfer invalidates reassessment notices issued by transferor officers and nullifies resulting proceed...
Consequential appeal-effect orders must implement rectification deleting working-capital adjustments and reconsider the resulting arm's-length range c...
Discounted cash flow valuation protects share premium where projections are reasonable, while audited book expenses defeat unexplained-expenditure add...
Section 54 construction relief survives pre-transfer commencement when completion occurs within the statutory period, excluding ineligible spouse-owne...
Consultancy and guidance supplied directly to a foreign client for its Indian business dealings do not constitute intermediary services where the consultant acts on its own account. Intermediary status requires three parties: a supplier of the principal service, its recipient, and a party performing the subsidiary role of arranging or facilitating that supply. Absence of a contractual relationship with Indian Railways and of any go-between function preserved the consultancy as a two-party service. The service therefore fell outside intermediary services, and the dropping of service tax, interest and penalty proceedings was upheld.
Consultancy and guidance supplied directly to a foreign client for its Indian business dealings do not constitute intermediary services where the consultant acts on its own account. Intermediary status requires three parties: a supplier of the principal service, its recipient, and a party performing the subsidiary role of arranging or facilitating that supply. Absence of a contractual relationship with Indian Railways and of any go-between function preserved the consultancy as a two-party service. The service therefore fell outside intermediary services, and the dropping of service tax, interest and penalty proceedings was upheld.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4888 
