Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
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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