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...
Liability to pay Service Tax when the main contractor has already paid - The Tribunal cited a circular stating sub-contractors are liable to pay Service Tax separately. However, they ruled the extended limitation period couldn't be invoked due to ambiguity during the relevant period. Regarding the normal limitation period, they upheld the demand for October 2010 to March 2011. They rejected the appellant's argument based on a Supreme Court case and noted that the demand for this period wasn't dead. Ultimately, they confirmed the demand for the normal period but set aside the extended period demand.
Liability to pay Service Tax when the main contractor has already paid - The Tribunal cited a circular stating sub-contractors are liable to pay Service Tax separately. However, they ruled the extended limitation period couldn't be invoked due to ambiguity during the relevant period. Regarding the normal limitation period, they upheld the demand for October 2010 to March 2011. They rejected the appellant's argument based on a Supreme Court case and noted that the demand for this period wasn't dead. Ultimately, they confirmed the demand for the normal period but set aside the extended period demand.
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