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...
Non-discharge of service tax - extended period invoked, service tax demanded - penalties imposed u/ss 77 and 78 of Finance Act, 1994 - appellant providing taxable maintenance, repair, manpower recruitment and supply services - appellant computed and paid service tax due - lack of knowledge and status as petty contractor pleaded - authorities imposed heavy penalties despite appellant's compliance before adjudication - undisputed findings regarding appellant's status and compliance - no justification for not considering Section 80 benefit and waiving penalties - fit case for waiving penalties u/ss 77 and 78 in terms of Section 80 - appeal partly allowed, setting aside penalties imposed on appellant.
Non-discharge of service tax - extended period invoked, service tax demanded - penalties imposed u/ss 77 and 78 of Finance Act, 1994 - appellant providing taxable maintenance, repair, manpower recruitment and supply services - appellant computed and paid service tax due - lack of knowledge and status as petty contractor pleaded - authorities imposed heavy penalties despite appellant's compliance before adjudication - undisputed findings regarding appellant's status and compliance - no justification for not considering Section 80 benefit and waiving penalties - fit case for waiving penalties u/ss 77 and 78 in terms of Section 80 - appeal partly allowed, setting aside penalties imposed on appellant.
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