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...
Failure to produce supporting documents before audit team does not constitute suppression of facts to invoke extended period of limitation u/s 73(1) of Finance Act, 1994. No allegation of statutory contravention with intent to evade tax against assessee. Not producing documents necessary for substantiating claim does not fall under exception of "suppression of facts". No express allegations made in show cause notice regarding suppression of facts. High Court concurred with CESTAT that extended period not correctly invoked as intent to evade tax neither established nor evident. No infirmity in CESTAT's decision rejecting Revenue's contention of invoking extended period under proviso to Section 73(1).
Failure to produce supporting documents before audit team does not constitute suppression of facts to invoke extended period of limitation u/s 73(1) of Finance Act, 1994. No allegation of statutory contravention with intent to evade tax against assessee. Not producing documents necessary for substantiating claim does not fall under exception of "suppression of facts". No express allegations made in show cause notice regarding suppression of facts. High Court concurred with CESTAT that extended period not correctly invoked as intent to evade tax neither established nor evident. No infirmity in CESTAT's decision rejecting Revenue's contention of invoking extended period under proviso to Section 73(1).
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