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...
Extended period of limitation - SCN issued beyond normal period - based on the books of accounts, maintained by the appellant, the officers of service tax department had conducted the audit and they have not disputed the authenticity or accuracy of records maintained by the appellant. - the appellant had received lesser amount than that as shown in the invoices issued to the service recipient. - the charges of suppression etc. cannot be levelled against the appellant. - AT
Extended period of limitation - SCN issued beyond normal period - based on the books of accounts, maintained by the appellant, the officers of service tax department had conducted the audit and they have not disputed the authenticity or accuracy of records maintained by the appellant. - the appellant had received lesser amount than that as shown in the invoices issued to the service recipient. - the charges of suppression etc. cannot be levelled against the appellant. - AT
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