Concessional corporate tax option under section 115BAA survives procedural documentary lapses when statutory compliance and earlier exercise are estab...
Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Levy of service tax - Employees were deputed to the assessee - receiving services from the overseas company FFECJ through Dispatch Agreement and Secondment Agreement in deployment of qualified and skilled employees during the said period - The Tribunal noted that the employees deputed to the respondent were under its control and direction, with no employer-employee relationship maintained with the overseas company during the assignment period. They upheld the Revenue’s contention regarding the taxability of the services. However, they ruled against the validity of invoking the extended period of limitation, finding no substantial evidence of suppression of facts by the respondent.
Levy of service tax - Employees were deputed to the assessee - receiving services from the overseas company FFECJ through Dispatch Agreement and Secondment Agreement in deployment of qualified and skilled employees during the said period - The Tribunal noted that the employees deputed to the respondent were under its control and direction, with no employer-employee relationship maintained with the overseas company during the assignment period. They upheld the Revenue’s contention regarding the taxability of the services. However, they ruled against the validity of invoking the extended period of limitation, finding no substantial evidence of suppression of facts by the respondent.
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