Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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Reversal of opening accrued and unbilled revenue already recognised and taxed in an earlier year was allowable where an indistinguishable coordinate-bench ruling applied; the related disallowance was deleted. Professional fees paid to non-residents were not established as royalty under the applicable tax treaty. Consequently, non-deduction of tax under section 195 did not justify disallowance, and deletion of that adjustment was sustained. The taxpayer's appeal succeeded, while the Revenue's appeal failed.
Reversal of opening accrued and unbilled revenue already recognised and taxed in an earlier year was allowable where an indistinguishable coordinate-bench ruling applied; the related disallowance was deleted. Professional fees paid to non-residents were not established as royalty under the applicable tax treaty. Consequently, non-deduction of tax under section 195 did not justify disallowance, and deletion of that adjustment was sustained. The taxpayer's appeal succeeded, while the Revenue's appeal failed.
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