Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Penalty u/s 78 of the FA, 1994 - appellant had correctly advised not to challenged the invocation of the extended period of limitation for recovery of service tax though the parameters/conditions for imposing equivalent penalty u/s 78 is same - appellant after having recovered the service tax from its customer had not paid over the amount to the State clearly point to mala fide conduct - penalty upheld
Penalty u/s 78 of the FA, 1994 - appellant had correctly advised not to challenged the invocation of the extended period of limitation for recovery of service tax though the parameters/conditions for imposing equivalent penalty u/s 78 is same - appellant after having recovered the service tax from its customer had not paid over the amount to the State clearly point to mala fide conduct - penalty upheld
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