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...
Levy of Service Tax - Incentive received - (i) the air travel agent is promoting its own business and is not promoting the business of the airlines; - (ii) the air travel agent is not promoting the business of the CRS Companies; - (iii) in any view of the matter, the classification of the service would fall under “air travel agent” service and not “BAS” in terms of the provisions of section 65A of the Finance Act; and - (iv) the incentives paid for achieving the targets are not leviable to service tax. - AT
Levy of Service Tax - Incentive received - (i) the air travel agent is promoting its own business and is not promoting the business of the airlines; - (ii) the air travel agent is not promoting the business of the CRS Companies; - (iii) in any view of the matter, the classification of the service would fall under “air travel agent” service and not “BAS” in terms of the provisions of section 65A of the Finance Act; and - (iv) the incentives paid for achieving the targets are not leviable to service tax. - AT
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