Intermediary service classification fails where overseas admission facilitation is supplied independently, preserving export treatment and small-provi...
Satellite transponder bandwidth is telecommunication, not Business Support Service; foreign non-telegraph providers triggered no service tax liability...
Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Competent sanction under section 151 is a substantive jurisdictional safeguard for reassessment. TOLA extended the authority under section 151(i) only until 30 June 2021; for notices issued in July 2022, approval from the higher authority under section 151(ii) was required. Approval by the Principal Commissioner was neither substantial compliance nor curable under section 292B, so the reassessment and consequential addition were annulled. Penalty for failure to obtain a tax audit requires proof of business activity and legally relevant turnover exceeding the prescribed threshold. Purchases, delivery-based sales and unproved derivative transactions could not establish turnover; consistent investment treatment and capital-gains disclosure also demonstrated reasonable cause. The audit penalty was deleted.
Competent sanction under section 151 is a substantive jurisdictional safeguard for reassessment. TOLA extended the authority under section 151(i) only until 30 June 2021; for notices issued in July 2022, approval from the higher authority under section 151(ii) was required. Approval by the Principal Commissioner was neither substantial compliance nor curable under section 292B, so the reassessment and consequential addition were annulled. Penalty for failure to obtain a tax audit requires proof of business activity and legally relevant turnover exceeding the prescribed threshold. Purchases, delivery-based sales and unproved derivative transactions could not establish turnover; consistent investment treatment and capital-gains disclosure also demonstrated reasonable cause. The audit penalty was deleted.
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