Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Levy of service tax - water charges paid - transfer of right to use the water by the Government to the appellant - Deemed sale - Since the agreement was for water supply, not services, the Tribunal found that service tax was not applicable to the water charges paid. - Considering the agreement's pre-2016 date, the Tribunal held that any services provided should be governed by pre-2016 provisions, exempting the appellant from tax liability. - Further, the Tribunal agreed with the appellant's argument that the water supply constituted the supply of goods, not services, aligning with the Finance Act's definition.
Levy of service tax - water charges paid - transfer of right to use the water by the Government to the appellant - Deemed sale - Since the agreement was for water supply, not services, the Tribunal found that service tax was not applicable to the water charges paid. - Considering the agreement's pre-2016 date, the Tribunal held that any services provided should be governed by pre-2016 provisions, exempting the appellant from tax liability. - Further, the Tribunal agreed with the appellant's argument that the water supply constituted the supply of goods, not services, aligning with the Finance Act's definition.
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