Departmental appeal limitation after call-book recall preserves original filing, while documented correlation supports SAD refund on imported granules...
Income-tax prosecution fails when appellate remand removes its factual foundation; directors require company arraignment for vicarious criminal liabil...
Capital character of assignment consideration prevents taxation as residuary income, while unsupported interest-related expenditure remains non-deduct...
Make-available condition shields regional support-service receipts from Indian taxation where no independent capability or permanent establishment exi...
Transfer-pricing treatment of corporate guarantees and convertible loans followed prior-year consistency, with taxable foreign dividends excluded from...
Clinical Research Organisations performing sponsor-approved clinical trials qualify for service-tax exemption on technical testing and analysis of newly developed drugs, even though regulatory approval is issued to the sponsor rather than separately to the CRO. Employee bond deposits forfeited on premature resignation are compensation for breach of an employment undertaking, not consideration for commercial training or coaching or for tolerating an act. Extended limitation requires deliberate suppression or other specified conduct with intent to evade tax; prior departmental disclosures and a tenable belief in exemption negate that requirement. Consequently, the technical-testing and training-related demands fail, with the latter also time-barred. Interest and penalties cannot survive where no principal tax demand or intent to evade is established.
Clinical Research Organisations performing sponsor-approved clinical trials qualify for service-tax exemption on technical testing and analysis of newly developed drugs, even though regulatory approval is issued to the sponsor rather than separately to the CRO. Employee bond deposits forfeited on premature resignation are compensation for breach of an employment undertaking, not consideration for commercial training or coaching or for tolerating an act. Extended limitation requires deliberate suppression or other specified conduct with intent to evade tax; prior departmental disclosures and a tenable belief in exemption negate that requirement. Consequently, the technical-testing and training-related demands fail, with the latter also time-barred. Interest and penalties cannot survive where no principal tax demand or intent to evade is established.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4883 
