Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
Automated Free Sale and Commerce Certificates enable paperless processing while retaining risk-based manual verification for selected exporter applica...
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Demand of service tax - receipts generated from securitization agreements - receipts from ‘special purpose vehicles’ - Barring a bald assertion that ‘cash management’ has been undertaken, the adjudicating authority has not made any effort to analyse the nature and circumstances in which the contract with ‘special purpose vehicles’ undertook to provide such facility. - The levy of tax and imposition of detriment in the impugned order is without authority of law - AT
Demand of service tax - receipts generated from securitization agreements - receipts from ‘special purpose vehicles’ - Barring a bald assertion that ‘cash management’ has been undertaken, the adjudicating authority has not made any effort to analyse the nature and circumstances in which the contract with ‘special purpose vehicles’ undertook to provide such facility. - The levy of tax and imposition of detriment in the impugned order is without authority of law - AT
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