Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Classification of service provided by company - Not Chartered Accountant Services or Market Research Agency's Services - Nature of services rendered includes consultancy, advice, assistance in mergers & acquisitions, due diligence, financial viability evaluation, classifiable under Management or Business Consultants Services. Services cannot be classified under Chartered Accountant Services as company is not engaged in practice of chartered accountancy or permitted by Institute of Chartered Accountants of India. Export of service - Services provided to PwC Overseas Network Firms, not directly to clients, qualify as export of services under Export of Services Rules, 2005 with consideration received in convertible foreign exchange. Time Limitation - Extended period of limitation not invocable as dispute involves interpretation of statutory provisions, no fraud or willful misstatement established. Interest and penalty - Not payable as demand of service tax itself unsustainable. Impugned order set aside, appeal allowed.
Classification of service provided by company - Not Chartered Accountant Services or Market Research Agency's Services - Nature of services rendered includes consultancy, advice, assistance in mergers & acquisitions, due diligence, financial viability evaluation, classifiable under Management or Business Consultants Services. Services cannot be classified under Chartered Accountant Services as company is not engaged in practice of chartered accountancy or permitted by Institute of Chartered Accountants of India. Export of service - Services provided to PwC Overseas Network Firms, not directly to clients, qualify as export of services under Export of Services Rules, 2005 with consideration received in convertible foreign exchange. Time Limitation - Extended period of limitation not invocable as dispute involves interpretation of statutory provisions, no fraud or willful misstatement established. Interest and penalty - Not payable as demand of service tax itself unsustainable. Impugned order set aside, appeal allowed.
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