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...
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Levy of Service Tax - collection of fees in discharge of sovereign functions - Instead of depositing the money to the Government, it is kept by the assessee - The same is the consideration received by the appellant for providing the Consultancy Service - this money cannot be equated with fee collected for discharging sovereign function. - Demand of service tax with penalty confirmed - AT
Levy of Service Tax - collection of fees in discharge of sovereign functions - Instead of depositing the money to the Government, it is kept by the assessee - The same is the consideration received by the appellant for providing the Consultancy Service - this money cannot be equated with fee collected for discharging sovereign function. - Demand of service tax with penalty confirmed - AT
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