Social forestry expenditure requires activity-based classification, limiting book-profit adjustments and preserving penalty relief where normal additi...
Inaccurate-particulars penalties fail where transfer-pricing documentation shows good faith and due diligence, and underlying capital-gains additions ...
Transfer-pricing tolerance for software sub-licensing falls within the services range, eliminating the adjustment and requiring TDS-credit verificatio...
Reasonable cause under Section 80 of the Finance Act, 1994 can shield an assessee from penalty under Section 78 for non-payment of service tax where contemporaneous departmental communications supported a bona fide belief that consultancy services provided to Government institutions were non-taxable. Interpretational uncertainty, the Department's initial view, and the absence of fraud, wilful misstatement, suppression with intent to evade, or deliberate default support reasonable cause. Service tax for the normal limitation period and applicable interest remained payable, but the Section 78 penalty was set aside.
Reasonable cause under Section 80 of the Finance Act, 1994 can shield an assessee from penalty under Section 78 for non-payment of service tax where contemporaneous departmental communications supported a bona fide belief that consultancy services provided to Government institutions were non-taxable. Interpretational uncertainty, the Department's initial view, and the absence of fraud, wilful misstatement, suppression with intent to evade, or deliberate default support reasonable cause. Service tax for the normal limitation period and applicable interest remained payable, but the Section 78 penalty was set aside.
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