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...
Demand of Differential Service Tax alongwith interest and penalty - It is not clear as to how the appellant has himself not accounted for the challans during the period of three years. Further as the appellant has unit at Bhubaneswar, there may be possibility these challans have been used for Service Tax to be paid by that Unit. Unless, the entire transaction of Kolkata Unit vis-à-vis their Bhubaneswar Unit is undertaken, the fact of challans not accounted, cannot be examined. - AT
Demand of Differential Service Tax alongwith interest and penalty - It is not clear as to how the appellant has himself not accounted for the challans during the period of three years. Further as the appellant has unit at Bhubaneswar, there may be possibility these challans have been used for Service Tax to be paid by that Unit. Unless, the entire transaction of Kolkata Unit vis-à-vis their Bhubaneswar Unit is undertaken, the fact of challans not accounted, cannot be examined. - AT
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