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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
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Levy of service tax on services received from foreign bank - The Tribunal determined that the appellant was not receiving any direct services from the foreign banks that warranted taxation. The banks provided services to other banks within India, which then interacted with the appellant. Any fees deducted by foreign banks were seen as inter-bank transactions, not services provided to the appellant. The Tribunal set aside the impugned orders and allowed the appeals of the appellant.
Levy of service tax on services received from foreign bank - The Tribunal determined that the appellant was not receiving any direct services from the foreign banks that warranted taxation. The banks provided services to other banks within India, which then interacted with the appellant. Any fees deducted by foreign banks were seen as inter-bank transactions, not services provided to the appellant. The Tribunal set aside the impugned orders and allowed the appeals of the appellant.
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