Additional evidence in departmental appeals may include show-cause-notice material without introducing a new case where it merely corroborates existin...
Reasoned rectification orders require consideration of expenditure disclosed in income-tax returns, preventing revision based on incomplete income com...
Modified returns after business reorganisations cannot trigger fresh scrutiny once the original assessment was complete, invalidating related transfer...
Third-party loose sheets require reliable nexus before supporting unexplained expenditure additions; presumptions do not establish payer identity or o...
TNMM comparability using audited accounts and working-capital adjustments can eliminate unwarranted transfer-pricing additions where verified margins ...
Gross-profit additions on disputed purchases require reasoned appellate determination; disclosed claims alone do not support inaccurate-particulars pe...
Limitation after transfer-pricing remand: fresh TPO reference did not extend the assessment deadline, rendering the consequential assessment time-barr...
Interim judicial restraint on tax deduction prevents default, while supporting reasonable cause and penalty deletion for foreign-leg LFC reimbursement...
Demand of service tax on the interest earned from hire purchase finance transactions. - The Tribunal observes that the ownership of the goods remains with the customers, and the Appellant only finances the purchase. There is no clause providing customers an option to purchase the product at the end of payment of all installments. Relying on the Supreme Court's decision, the Tribunal distinguishes between hire purchase agreements and hire purchase finance agreements. - Demand set aside.
Demand of service tax on the interest earned from hire purchase finance transactions. - The Tribunal observes that the ownership of the goods remains with the customers, and the Appellant only finances the purchase. There is no clause providing customers an option to purchase the product at the end of payment of all installments. Relying on the Supreme Court's decision, the Tribunal distinguishes between hire purchase agreements and hire purchase finance agreements. - Demand set aside.
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