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...
Levy of Service Tax - foreign remittances - market research and exploration executed outside India - Though market research and exploration have not been specifically stated in the contract, but still the scope of the work clearly suggests that the contract is basically for the work of market research and exploration which would be taxable under section 65(105)(y) of the Finance Act but in view of the provisions of rule 3(ii) of the Import Rules, no service tax would be payable. - AT
Levy of Service Tax - foreign remittances - market research and exploration executed outside India - Though market research and exploration have not been specifically stated in the contract, but still the scope of the work clearly suggests that the contract is basically for the work of market research and exploration which would be taxable under section 65(105)(y) of the Finance Act but in view of the provisions of rule 3(ii) of the Import Rules, no service tax would be payable. - AT
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