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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The case before CESTAT involved the classification of "convenience fee" and "cancellation charges" as either Air Travel Agent Services or Business Auxiliary Services. CESTAT held that these fees, collected by the appellant, were not part of any other service provided. The charges were found to relate solely to the service of booking air tickets. CESTAT also determined that the fees did not attract additional service tax liability before or after 01.07.2012. The tribunal rejected the imposition of penalties, citing lack of evidence of intent to evade duty and the appellant's belief that the fees were not taxable. The appeal was allowed in favor of the appellant.
The case before CESTAT involved the classification of "convenience fee" and "cancellation charges" as either Air Travel Agent Services or Business Auxiliary Services. CESTAT held that these fees, collected by the appellant, were not part of any other service provided. The charges were found to relate solely to the service of booking air tickets. CESTAT also determined that the fees did not attract additional service tax liability before or after 01.07.2012. The tribunal rejected the imposition of penalties, citing lack of evidence of intent to evade duty and the appellant's belief that the fees were not taxable. The appeal was allowed in favor of the appellant.
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