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Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Classification of services - a co-loader / courier agency - Whatever the evidence placed on record indicate that the appellant has rendered services to other courier agencies and was not involved in the in-transit movement of courier parcels to be called a “co-loader”. According to the appellant, courier parcels were collected from various customers in its jurisdiction which were reportedly sent abroad through M/s. United Business Xpress India Pvt. Ltd., New Delhi. It is not possible, in the absence of any documentary evidence i.e., any agreement / contract / terms of payment for rendering these services, to determine that its services are that of a co-loader. - AT
Classification of services - a co-loader / courier agency - Whatever the evidence placed on record indicate that the appellant has rendered services to other courier agencies and was not involved in the in-transit movement of courier parcels to be called a “co-loader”. According to the appellant, courier parcels were collected from various customers in its jurisdiction which were reportedly sent abroad through M/s. United Business Xpress India Pvt. Ltd., New Delhi. It is not possible, in the absence of any documentary evidence i.e., any agreement / contract / terms of payment for rendering these services, to determine that its services are that of a co-loader. - AT
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