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...
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Levy of penalty u/s 78 of FA - allegation of evasion of service tax - The assessee being a public sector undertaking of the Government of India is an additional factor to hold that any mala fide intention to evade payment of Service Tax would not be attributed, to levy penalty under Section 78 ibid. - AT
Levy of penalty u/s 78 of FA - allegation of evasion of service tax - The assessee being a public sector undertaking of the Government of India is an additional factor to hold that any mala fide intention to evade payment of Service Tax would not be attributed, to levy penalty under Section 78 ibid. - AT
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