Reassessment sanction under extended limitation required approval from the competent specified authority, invalidating proceedings approved by an inco...
Internal CUP benchmarking for fixed-rate Masala Bonds prevails over floating external comparables, eliminating the related transfer-pricing adjustment...
Jurisdictional validity of revision notices: incorrect official capacity and mere change of opinion invalidate revision of property income assessments...
CENVAT credit on input services received at premises omitted from a centralised registration cannot be denied solely because those premises are unregistered. In contrast, works contract services used to construct or set up BPO branches fall within the exclusion for construction of buildings or civil structures, making related credit inadmissible. Where disputed credit was disclosed in ST-3 returns and refund claims, audit detection alone does not establish suppression or other conditions for extended limitation; recovery is confined to the normal period and requires recomputation. Interest follows on recoverable inadmissible credit, but penalties based on suppression or failure to include premises are unsustainable without the requisite contravention or intent to evade.
CENVAT credit on input services received at premises omitted from a centralised registration cannot be denied solely because those premises are unregistered. In contrast, works contract services used to construct or set up BPO branches fall within the exclusion for construction of buildings or civil structures, making related credit inadmissible. Where disputed credit was disclosed in ST-3 returns and refund claims, audit detection alone does not establish suppression or other conditions for extended limitation; recovery is confined to the normal period and requires recomputation. Interest follows on recoverable inadmissible credit, but penalties based on suppression or failure to include premises are unsustainable without the requisite contravention or intent to evade.
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