Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
Vicarious liability for dishonoured company cheques may extend to non-signatory directors where complaints contain foundational responsibility avermen...
The Appellate Tribunal addressed various issues: 1. Validity of assessment - Notice u/s 143(2) properly issued. 2. Tax rate for domestic companies - Non-discrimination clause of India-France Tax Treaty upheld. 3. Taxability of data processing fees - Charges to overseas branch not taxable. 4. Taxability of interest paid by branch office - Interest not taxable under DTAA if connected to Permanent Establishment in India. Tribunal ruled in favor of the assessee on all counts, rejecting Revenue's claims.
The Appellate Tribunal addressed various issues: 1. Validity of assessment - Notice u/s 143(2) properly issued. 2. Tax rate for domestic companies - Non-discrimination clause of India-France Tax Treaty upheld. 3. Taxability of data processing fees - Charges to overseas branch not taxable. 4. Taxability of interest paid by branch office - Interest not taxable under DTAA if connected to Permanent Establishment in India. Tribunal ruled in favor of the assessee on all counts, rejecting Revenue's claims.
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