Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Service tax demand on income shown in Income Tax Return - Suppression of facts and contravention of Act/Rules with intent to evade tax - Extended period of limitation rightly invoked as appellant filed ST-3 Returns without fully disclosing taxable value - Differential value learnt from Income Tax Department - Penalty u/ss 78 and 77 upheld along with interest - No merits to interfere with impugned order - Appeal dismissed.
Service tax demand on income shown in Income Tax Return - Suppression of facts and contravention of Act/Rules with intent to evade tax - Extended period of limitation rightly invoked as appellant filed ST-3 Returns without fully disclosing taxable value - Differential value learnt from Income Tax Department - Penalty u/ss 78 and 77 upheld along with interest - No merits to interfere with impugned order - Appeal dismissed.
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