Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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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