Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Recovery of service tax alongwith interest and penalty - Extended period of Limitation- The tribunal found that the appellant had disclosed their CENVAT credit in their tax returns, negating claims of willful suppression of facts. Furthermore, it was determined that the extended period of limitation was incorrectly applied by the authorities, as the issue of taxing renting of immovable property was under judicial scrutiny during the relevant period. Consequently, the tribunal allowed the appeal, setting aside the demand for service tax and penalties as barred by limitation.
Recovery of service tax alongwith interest and penalty - Extended period of Limitation- The tribunal found that the appellant had disclosed their CENVAT credit in their tax returns, negating claims of willful suppression of facts. Furthermore, it was determined that the extended period of limitation was incorrectly applied by the authorities, as the issue of taxing renting of immovable property was under judicial scrutiny during the relevant period. Consequently, the tribunal allowed the appeal, setting aside the demand for service tax and penalties as barred by limitation.
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