Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Extended period of limitation - suppression of facts or not - It is for the Superintendent to scrutinize the returns and ascertain if the service tax had been paid correctly or not. - The fact that the alleged short payment came to light only during audit does not prove the intent to evade payment of service tax by the appellant, but it only proves that the Range Superintendent had not done his job properly. For these reasons, it is found that the demand for the extended period of limitation cannot be sustained. - AT
Extended period of limitation - suppression of facts or not - It is for the Superintendent to scrutinize the returns and ascertain if the service tax had been paid correctly or not. - The fact that the alleged short payment came to light only during audit does not prove the intent to evade payment of service tax by the appellant, but it only proves that the Range Superintendent had not done his job properly. For these reasons, it is found that the demand for the extended period of limitation cannot be sustained. - AT
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