Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
The Tribunal examines whether the services provided by the OLSPs to the Appellant fall under the category of "Business Auxiliary Service" as defined in the Finance Act, 1994. It concludes that since the OLSPs are not acting as agents of the Appellant, the services provided by them cannot be taxed under the specified category. - The CESTAT finds that the Show Cause Notice lacks specificity regarding the sub-clause of Section 65(19) under which the demand is raised. It rules that such a defect in the notice cannot be rectified by observations made by the adjudicating authority.
The Tribunal examines whether the services provided by the OLSPs to the Appellant fall under the category of "Business Auxiliary Service" as defined in the Finance Act, 1994. It concludes that since the OLSPs are not acting as agents of the Appellant, the services provided by them cannot be taxed under the specified category. - The CESTAT finds that the Show Cause Notice lacks specificity regarding the sub-clause of Section 65(19) under which the demand is raised. It rules that such a defect in the notice cannot be rectified by observations made by the adjudicating authority.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
