Invoice-based recovery claims remain time-barred despite separate winding-up proceedings, absent valid acknowledgment or part-payment of the disputed ...
Extended limitation fails without specific suppression allegations, while overseas employee secondment remains taxable as manpower supply within norma...
Time-share accommodation classification excludes Club or Association Service where purchasers receive contractual occupancy rights without genuine mem...
CENVAT credit for trading requires reversal, while taxable-service rental credit remains proportionately available and limitation issues await resolut...
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Time limitation for passing an order u/s 92CA is a contentious issue. The Tribunal followed the Madras High Court's decision in Pfizer Healthcare, but the Revenue has filed an SLP challenging it before the Supreme Court. Interpretation of Section 92CA's interplay with Section 153 regarding limitation is pending consideration by the Supreme Court. The Bombay High Court's order in PayPal Payments is also challenged before the Supreme Court. To avoid multiplicity of proceedings, the appeals are adjourned sine die, awaiting the Supreme Court's rulings on these issues. Proceeding otherwise would necessitate cross-appeals, adding to the multiplicity.
Time limitation for passing an order u/s 92CA is a contentious issue. The Tribunal followed the Madras High Court's decision in Pfizer Healthcare, but the Revenue has filed an SLP challenging it before the Supreme Court. Interpretation of Section 92CA's interplay with Section 153 regarding limitation is pending consideration by the Supreme Court. The Bombay High Court's order in PayPal Payments is also challenged before the Supreme Court. To avoid multiplicity of proceedings, the appeals are adjourned sine die, awaiting the Supreme Court's rulings on these issues. Proceeding otherwise would necessitate cross-appeals, adding to the multiplicity.
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