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...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Taxability of service tax on transporting goods by road covered u/s 66D(p), appellant not being GTA or courier agency, amount towards facilitation of freight and insurance by appellant, service tax demand wrongly raised. Reversal of Cenvat credit denied on services of hiring water tankers, mechanized canteen cleaning, catering services as per Sections 44 and 46 of Factory Act, credit rightly availed. Services like hotel accommodation for personnel imparting training to employees, not for personal use, credit rightly availed. Meaning of terms "includes", "in relation to", "such as" discussed based on judicial precedents. Credit on short-term accommodation/hotel services for inspection and testing of goods by customers, directly related to manufacturing, denial of credit not sustainable. Order under challenge set aside, appeal allowed.
Taxability of service tax on transporting goods by road covered u/s 66D(p), appellant not being GTA or courier agency, amount towards facilitation of freight and insurance by appellant, service tax demand wrongly raised. Reversal of Cenvat credit denied on services of hiring water tankers, mechanized canteen cleaning, catering services as per Sections 44 and 46 of Factory Act, credit rightly availed. Services like hotel accommodation for personnel imparting training to employees, not for personal use, credit rightly availed. Meaning of terms "includes", "in relation to", "such as" discussed based on judicial precedents. Credit on short-term accommodation/hotel services for inspection and testing of goods by customers, directly related to manufacturing, denial of credit not sustainable. Order under challenge set aside, appeal allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
