Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Extended period of limitation - Recovery of service tax - service being taxable but the liability has not been discharged by the appellant - the Department has wrongly invoked the extended period of limitation. - nothing of this sort is apparent on part of the appellant - Department has wrongly invoked the extended period of limitation. Both the SCNs are therefore, held to be barred by the period of limitation. - AT
Extended period of limitation - Recovery of service tax - service being taxable but the liability has not been discharged by the appellant - the Department has wrongly invoked the extended period of limitation. - nothing of this sort is apparent on part of the appellant - Department has wrongly invoked the extended period of limitation. Both the SCNs are therefore, held to be barred by the period of limitation. - AT
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