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...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Extended period of limitation - liability of a subcontractor to pay service tax - The High court concluded that the interpretation issue regarding subcontractor liability was unsettled until a later decision in 2019. Therefore, the respondent's actions were considered bona fide, and the failure to disclose the payment of service tax did not constitute suppression of facts. - Consequently, the court upheld the Tribunal's decision to remit the case back to the Commissioner without invoking the proviso to extend the period of limitation.
Extended period of limitation - liability of a subcontractor to pay service tax - The High court concluded that the interpretation issue regarding subcontractor liability was unsettled until a later decision in 2019. Therefore, the respondent's actions were considered bona fide, and the failure to disclose the payment of service tax did not constitute suppression of facts. - Consequently, the court upheld the Tribunal's decision to remit the case back to the Commissioner without invoking the proviso to extend the period of limitation.
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