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...
Service tax demand amounting to Rs. 18,95,70,056/- for 2007-08 to 2011-12 and Rs. 22,47,16,252/- for 2012-13 was dropped by adjudicating authority on account of short payment of service tax on Works Contract Service. Relying on CESTAT decisions, it held that service tax was leviable only on payments received, not on accrual basis. Appellant submitted CA certificate, shifting onus on department to negate it. Department failed to provide contrary evidence. Estimated inflated demand based on previous year's turnover was rightly rejected. No infirmity found in impugned order, hence appeal dismissed.
Service tax demand amounting to Rs. 18,95,70,056/- for 2007-08 to 2011-12 and Rs. 22,47,16,252/- for 2012-13 was dropped by adjudicating authority on account of short payment of service tax on Works Contract Service. Relying on CESTAT decisions, it held that service tax was leviable only on payments received, not on accrual basis. Appellant submitted CA certificate, shifting onus on department to negate it. Department failed to provide contrary evidence. Estimated inflated demand based on previous year's turnover was rightly rejected. No infirmity found in impugned order, hence appeal dismissed.
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