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...
Bogus-purchase additions are limited to embedded profit where corresponding sales are accepted, while accommodation-entry information can support reas...
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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