Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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