Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Sub-contractors liable to pay Service Tax even if main contractor pays tax on entire amount after 23.08.2007 circular, earlier confusion on issue. Appellant entered agreement in 2004, main contractor paid Service Tax, appellant did not pay as sub-contractor. No suppression of facts or intention to evade tax established. Extended period limitation demand not sustainable. Remanded to calculate normal period liability, if any. Appellant liable for Service Tax and interest for normal period. Demand for extended period set aside, appeal allowed by way of remand.
Sub-contractors liable to pay Service Tax even if main contractor pays tax on entire amount after 23.08.2007 circular, earlier confusion on issue. Appellant entered agreement in 2004, main contractor paid Service Tax, appellant did not pay as sub-contractor. No suppression of facts or intention to evade tax established. Extended period limitation demand not sustainable. Remanded to calculate normal period liability, if any. Appellant liable for Service Tax and interest for normal period. Demand for extended period set aside, appeal allowed by way of remand.
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