Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Adjustment of advance of service tax was paid but had not been shown in the ST-3 Return as advances and not been adjusted subsequently - Under Rule 6 of the Service Tax Rules, the advance payment of Service Tax can be adjusted against subsequent Service Tax dues. The appellant had discharged the duty liability but failed to record the same in the ST-3 Returns due to inadequate understanding of the law. - Adjustment allowed - Only the late filing fee/ penalty u/s 77(2) confirmed. - AT
Adjustment of advance of service tax was paid but had not been shown in the ST-3 Return as advances and not been adjusted subsequently - Under Rule 6 of the Service Tax Rules, the advance payment of Service Tax can be adjusted against subsequent Service Tax dues. The appellant had discharged the duty liability but failed to record the same in the ST-3 Returns due to inadequate understanding of the law. - Adjustment allowed - Only the late filing fee/ penalty u/s 77(2) confirmed. - AT
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