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...
The appellant was liable to pay service tax on banking and financial services, but their failure to do so was not willful or deliberate. The non-disclosure of certain assessable items does not attract the extended period of limitation under the proviso to Section 73 of the Finance Act, 1994. No penalty is imposable on the appellant, but they must pay interest on the belated payment of tax u/s 75 of the Finance Act, 1994. The High Court partially allowed the appeal, holding that no penalty is payable by the appellant under any provisions of the Act, but they must pay interest on the belated tax payment.
The appellant was liable to pay service tax on banking and financial services, but their failure to do so was not willful or deliberate. The non-disclosure of certain assessable items does not attract the extended period of limitation under the proviso to Section 73 of the Finance Act, 1994. No penalty is imposable on the appellant, but they must pay interest on the belated payment of tax u/s 75 of the Finance Act, 1994. The High Court partially allowed the appeal, holding that no penalty is payable by the appellant under any provisions of the Act, but they must pay interest on the belated tax payment.
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