Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Validity of SCN - SCN suffers from incurable deficiency - Demand raised solely on the basis of Income Tax data shared by the Income Tax authorities - CESTAT found that the orders confirming the service tax demand were beyond the scope of the SCN and did not specify the clause under which the service fell for taxability. - The tribunal interpreted Section 65(91a) of the Finance Act, 1994, and determined that the appellant's activities did not constitute the construction of a residential complex liable for service tax. - The tribunal set aside the service tax demand upheld by the impugned orders, ruling in favor of the appellant.
Validity of SCN - SCN suffers from incurable deficiency - Demand raised solely on the basis of Income Tax data shared by the Income Tax authorities - CESTAT found that the orders confirming the service tax demand were beyond the scope of the SCN and did not specify the clause under which the service fell for taxability. - The tribunal interpreted Section 65(91a) of the Finance Act, 1994, and determined that the appellant's activities did not constitute the construction of a residential complex liable for service tax. - The tribunal set aside the service tax demand upheld by the impugned orders, ruling in favor of the appellant.
Note: It is a system-generated summary and is for quick reference only.