Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
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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