Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Service tax exemption under Notification No. 25/2012-ST denied for services of laying cable under NOFN project, as the project aimed at increasing subscriber base and revenues for BSNL, falling within the ambit of 'commerce'. Notification exempts civil structures meant predominantly for use other than commerce, industry or business, which is to be interpreted strictly. Appellant not eligible for exemption. Non-recovery of service tax is an offence u/s 73. Cum-duty benefit allowed, directing recalculation of demand treating receipts as inclusive of service tax and consequential re-computation of penalty u/s 78.
Service tax exemption under Notification No. 25/2012-ST denied for services of laying cable under NOFN project, as the project aimed at increasing subscriber base and revenues for BSNL, falling within the ambit of 'commerce'. Notification exempts civil structures meant predominantly for use other than commerce, industry or business, which is to be interpreted strictly. Appellant not eligible for exemption. Non-recovery of service tax is an offence u/s 73. Cum-duty benefit allowed, directing recalculation of demand treating receipts as inclusive of service tax and consequential re-computation of penalty u/s 78.
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