Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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