Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Short/non-payment of service tax - Jurisdiction to raise the Demand - The Tribunal notes that during the period in question, the Appellant was registered in Mumbai and paid Service Tax accordingly. As the transactions were conducted under the Mumbai jurisdiction, the Kolkata Revenue officials lacked jurisdiction to demand Service Tax. Therefore, the Tribunal sets aside the demand for the period under the extended period of limitation.
Short/non-payment of service tax - Jurisdiction to raise the Demand - The Tribunal notes that during the period in question, the Appellant was registered in Mumbai and paid Service Tax accordingly. As the transactions were conducted under the Mumbai jurisdiction, the Kolkata Revenue officials lacked jurisdiction to demand Service Tax. Therefore, the Tribunal sets aside the demand for the period under the extended period of limitation.
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