Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Interest liability - seeking waiver of interest since the payment of service tax was paid under the amnesty scheme - The tribunal observed that the appellant's payment of service tax, even under an amnesty scheme, necessitated interest payment as a corollary. Therefore, the appellant's contention for exemption from interest payment was deemed untenable. Regarding the refund claim, the tribunal affirmed that the appellant's payment of service tax without contestation implied acceptance of the department's stance. Additionally, the tribunal reasoned that the amnesty scheme, under which the appellant paid the tax, did not absolve them from interest liability.
Interest liability - seeking waiver of interest since the payment of service tax was paid under the amnesty scheme - The tribunal observed that the appellant's payment of service tax, even under an amnesty scheme, necessitated interest payment as a corollary. Therefore, the appellant's contention for exemption from interest payment was deemed untenable. Regarding the refund claim, the tribunal affirmed that the appellant's payment of service tax without contestation implied acceptance of the department's stance. Additionally, the tribunal reasoned that the amnesty scheme, under which the appellant paid the tax, did not absolve them from interest liability.
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TaxTMI 
TaxTMI 
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