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 - Business Support services - The impugned order has confirmed the demand on the basis that the appellant provided ‘infrastructure support services’ to the appellant. However, the show cause notice alleged that the appellant was providing ‘operational and administrative assistance’ with supplier. The Commissioner could not have gone beyond the scope of the show cause notice to confirm the demand. - AT
Levy of service tax - Business Support services - The impugned order has confirmed the demand on the basis that the appellant provided ‘infrastructure support services’ to the appellant. However, the show cause notice alleged that the appellant was providing ‘operational and administrative assistance’ with supplier. The Commissioner could not have gone beyond the scope of the show cause notice to confirm the demand. - AT
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