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...
Non-payment of service tax - The Appellate Tribunal held that the demand was not sustainable due to being beyond the limitation period, as the department was aware of the appellant's activities. - It ruled that the appellant's activities did not qualify as Business Support Service, as they were primarily in the public interest, not for promoting private business. - However, the Tribunal found the appellant liable to pay service tax under the category of Renting of Immovable Property Service, as the properties were rented out for commercial purposes. - The demand under Sale of Space and Time for Advertisement Service was deemed not sustainable due to being beyond the limitation period.
Non-payment of service tax - The Appellate Tribunal held that the demand was not sustainable due to being beyond the limitation period, as the department was aware of the appellant's activities. - It ruled that the appellant's activities did not qualify as Business Support Service, as they were primarily in the public interest, not for promoting private business. - However, the Tribunal found the appellant liable to pay service tax under the category of Renting of Immovable Property Service, as the properties were rented out for commercial purposes. - The demand under Sale of Space and Time for Advertisement Service was deemed not sustainable due to being beyond the limitation period.
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