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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Non-profit organization registered u/s 12AA of Income Tax Act, 1961 - alleged violation of Finance Act and Service Tax Rules - applicability of mega exemption notification and negative list exemption - HELD: Appellant's activity covered under Entry No. 9 of mega exemption notification exempting services by any person other than business entity - appellant a statutory body carrying out functions under Architects Act without commercial motive - fees collected for regulatory purposes like inspection, approval of institutions, promotion of architectural education - appellant registered as charitable trust under IT Act - department's circular clarifying exemption for educational institutions - prior circular stating no service tax on statutory functions by sovereign/public authorities - CESTAT ruling fees deposited in government treasury for mandatory statutory functions not taxable service - appellant complying with quantitative limit for charitable purpose under IT Act - demand set aside, appeal allowed.
Non-profit organization registered u/s 12AA of Income Tax Act, 1961 - alleged violation of Finance Act and Service Tax Rules - applicability of mega exemption notification and negative list exemption - HELD: Appellant's activity covered under Entry No. 9 of mega exemption notification exempting services by any person other than business entity - appellant a statutory body carrying out functions under Architects Act without commercial motive - fees collected for regulatory purposes like inspection, approval of institutions, promotion of architectural education - appellant registered as charitable trust under IT Act - department's circular clarifying exemption for educational institutions - prior circular stating no service tax on statutory functions by sovereign/public authorities - CESTAT ruling fees deposited in government treasury for mandatory statutory functions not taxable service - appellant complying with quantitative limit for charitable purpose under IT Act - demand set aside, appeal allowed.
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