Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Demand of service tax - SEBI - ‘negative list regime’ - demand of tax on the fees collected - We cannot but withhold our ascertainment of the legality of the claim made by the appellant before us. - it is difficult to conceive of any motive in not complying with tax liabilities. There is also no allegation of suppression or misrepresentation by the appellant. - The demand for the period beyond normal limitation, therefore, does not sustain - Consequently, the penalty under section 78 of Finance Act, 1994 is set aside. - AT
Demand of service tax - SEBI - ‘negative list regime’ - demand of tax on the fees collected - We cannot but withhold our ascertainment of the legality of the claim made by the appellant before us. - it is difficult to conceive of any motive in not complying with tax liabilities. There is also no allegation of suppression or misrepresentation by the appellant. - The demand for the period beyond normal limitation, therefore, does not sustain - Consequently, the penalty under section 78 of Finance Act, 1994 is set aside. - AT
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