Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Reverse-charge liability on foreign or intermediary bank charges deducted while transmitting export proceeds requires a taxable service provider-recipient relationship. Where the exporter neither engaged the banks nor owed them consideration, deductions from export proceeds do not establish that relationship and do not attract service tax under Banking and Other Financial Services. Regulatory dossier preparation and compilation for overseas pharmaceutical approvals must be classified by the activity actually performed, not the provider's technical qualifications. Preparing documentation from available information or published literature, without advice or scientific or technical assistance, is not Scientific or Technical Consultancy Service. The related service-tax demands, interest and penalties were unsustainable.
Reverse-charge liability on foreign or intermediary bank charges deducted while transmitting export proceeds requires a taxable service provider-recipient relationship. Where the exporter neither engaged the banks nor owed them consideration, deductions from export proceeds do not establish that relationship and do not attract service tax under Banking and Other Financial Services. Regulatory dossier preparation and compilation for overseas pharmaceutical approvals must be classified by the activity actually performed, not the provider's technical qualifications. Preparing documentation from available information or published literature, without advice or scientific or technical assistance, is not Scientific or Technical Consultancy Service. The related service-tax demands, interest and penalties were unsustainable.
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