Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Tour operator service definition requires primary engagement of planning, scheduling, organizing tours by mode of transport covered by permit under Motor Vehicles Act, 1988; standalone hotel accommodation arrangement cannot be classified as tour operator service. Hotel accommodation service was brought under service tax net from 01.05.2011; prior non-taxability and double taxation avoidance principle discussed. Extended period limitation invoked erroneously as facts were known; when service tax itself not leviable, extended period cannot be invoked. Commissioner's order set aside; appeal allowed.
Tour operator service definition requires primary engagement of planning, scheduling, organizing tours by mode of transport covered by permit under Motor Vehicles Act, 1988; standalone hotel accommodation arrangement cannot be classified as tour operator service. Hotel accommodation service was brought under service tax net from 01.05.2011; prior non-taxability and double taxation avoidance principle discussed. Extended period limitation invoked erroneously as facts were known; when service tax itself not leviable, extended period cannot be invoked. Commissioner's order set aside; appeal allowed.
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