Minimum alternate tax exclusions for pre-amendment banking companies and expatriate Indian branch salaries remain outside head office expenditure limi...
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Levy of service tax - receipt of intellectual property service from the overseas entity - consequence of merger - The adjudicating authority has failed to consider the deemed demutualization of amalgamated entity and amalgamating entities for the period prior to effective merger and has superficially applied the appointed date conundrum to the ‘no brainer’, and default, articulation in section 66A of Finance Act, 1994 without taking in the entire canvass of this special provision of law to charge tax on specifically intended transactions. - AT
Levy of service tax - receipt of intellectual property service from the overseas entity - consequence of merger - The adjudicating authority has failed to consider the deemed demutualization of amalgamated entity and amalgamating entities for the period prior to effective merger and has superficially applied the appointed date conundrum to the ‘no brainer’, and default, articulation in section 66A of Finance Act, 1994 without taking in the entire canvass of this special provision of law to charge tax on specifically intended transactions. - AT
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