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...
The case involves a dispute u/s classification of services for tax purposes. The appellant provided services as a sub-contractor for printing voter rolls and cards. The services were classified as Business Auxiliary Services due to commission-based arrangement with UPDESCO. The liability to pay service tax as a sub-contractor was upheld, following precedent. The extended period of limitation for penalty was questioned, with the need for verification of tax payments post 01.07.2010. The imposition of penalty u/s 76 for the period prior to 09.05.2008 was deemed unjustified due to limitation. The appeal was partially allowed, remanding for re-computation of tax liability for the normal period.
The case involves a dispute u/s classification of services for tax purposes. The appellant provided services as a sub-contractor for printing voter rolls and cards. The services were classified as Business Auxiliary Services due to commission-based arrangement with UPDESCO. The liability to pay service tax as a sub-contractor was upheld, following precedent. The extended period of limitation for penalty was questioned, with the need for verification of tax payments post 01.07.2010. The imposition of penalty u/s 76 for the period prior to 09.05.2008 was deemed unjustified due to limitation. The appeal was partially allowed, remanding for re-computation of tax liability for the normal period.
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