Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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...
Service tax Liability - extended period of limitation - The bona fide belief with regard to non taxability of sale of space for advertisement gets clearly established. The appellant were regularly filing their ST-3 returns. It was known to the department that the appellant was paying Service tax prior to 01.07.2012 and also started paying Service Tax from 01.10.2014 and interregnum period the entry of space for advertisement was under Negative List. Therefore, we do not see any suppression of fact or the mala fide intention on the part of the appellant for non-payment of service tax. - AT
Service tax Liability - extended period of limitation - The bona fide belief with regard to non taxability of sale of space for advertisement gets clearly established. The appellant were regularly filing their ST-3 returns. It was known to the department that the appellant was paying Service tax prior to 01.07.2012 and also started paying Service Tax from 01.10.2014 and interregnum period the entry of space for advertisement was under Negative List. Therefore, we do not see any suppression of fact or the mala fide intention on the part of the appellant for non-payment of service tax. - AT
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