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...
Appellant engaged in multi-level sales promotion activities, selling vouchers for gifts, holidays and airline tickets to corporate clients. Classified services under 'Tour Operator' and availed abatement, but demand raised under 'Business Auxiliary Service'. Held appellant directly provided services to customers without corporate intervention, rightly classified under 'Tour Operator' and availed abatement. Extended period invoked solely based on audit without evidence of intent to evade tax, appellant filing returns declaring abatement, hence not sustainable. No demand sustainable, so no interest or penalty payable. Impugned order set aside by Appellate Tribunal.
Appellant engaged in multi-level sales promotion activities, selling vouchers for gifts, holidays and airline tickets to corporate clients. Classified services under 'Tour Operator' and availed abatement, but demand raised under 'Business Auxiliary Service'. Held appellant directly provided services to customers without corporate intervention, rightly classified under 'Tour Operator' and availed abatement. Extended period invoked solely based on audit without evidence of intent to evade tax, appellant filing returns declaring abatement, hence not sustainable. No demand sustainable, so no interest or penalty payable. Impugned order set aside by Appellate Tribunal.
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TaxTMI 
TaxTMI 
of 4918 
