Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
Leasing of DG Sets does not constitute supply of tangible goods for use service, as the transaction is in the nature of deemed sale under Article 366(29A) of the Constitution of India. Despite the removal of individual service definition post 01.07.2012, deemed sale continues to be excluded from service tax purview. Consequently, the activity of leasing DG Sets is not liable to service tax, and the impugned order is set aside, with the appeal allowed.
Leasing of DG Sets does not constitute supply of tangible goods for use service, as the transaction is in the nature of deemed sale under Article 366(29A) of the Constitution of India. Despite the removal of individual service definition post 01.07.2012, deemed sale continues to be excluded from service tax purview. Consequently, the activity of leasing DG Sets is not liable to service tax, and the impugned order is set aside, with the appeal allowed.
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