Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Extended period of limitation - Demand based on Form 26AS (TDS Statement) - The Notice in this case was issued on 08.09.2021, demanding service tax for the period 2016-17. The Department has not adduced any positive evidence to show malafide intention or mens rea for evasion of Service Tax on the part of the Appellant. Thus, the extended period cannot be invoked in this case to demand service tax on the Appellant. - AT
Extended period of limitation - Demand based on Form 26AS (TDS Statement) - The Notice in this case was issued on 08.09.2021, demanding service tax for the period 2016-17. The Department has not adduced any positive evidence to show malafide intention or mens rea for evasion of Service Tax on the part of the Appellant. Thus, the extended period cannot be invoked in this case to demand service tax on the Appellant. - AT
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