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...
Exemption from service tax provided to DMRC - Railways - composite contacts - works contract service - The exclusion of the alleged ‘taxable service’ sought to be fastened on them from any contract other than service simpliciter erases the distinction of commercial outcome suggested by the reviewing authority. In any case, even if Delhi Metro Rail Corporation were to be the final recipient of the service rendered by the respondent, the decision of the Hon’ble High Court of Calcutta in M/s Afcons Infrastructure Ltd. categorising them as ‘railway’ forecloses taxability even if the dispute pertains to laying of water pipelines. - AT
Exemption from service tax provided to DMRC - Railways - composite contacts - works contract service - The exclusion of the alleged ‘taxable service’ sought to be fastened on them from any contract other than service simpliciter erases the distinction of commercial outcome suggested by the reviewing authority. In any case, even if Delhi Metro Rail Corporation were to be the final recipient of the service rendered by the respondent, the decision of the Hon’ble High Court of Calcutta in M/s Afcons Infrastructure Ltd. categorising them as ‘railway’ forecloses taxability even if the dispute pertains to laying of water pipelines. - AT
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TaxTMI 
TaxTMI 
of 4918 
