Tax exemption for specified legal-services authority income applies retrospectively, subject to non-commercial activity, unchanged income sources, and...
Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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Extended period of limitation of five years: Mere non-disclosure of receipts in the service tax return does not automatically mean there was an intent to evade payment of service tax. Suppression of facts has to be willful and with an intent to evade tax, as held by the Supreme Court. In this case, the department had already scrutinized the records earlier, and the show cause notice was based on entries available in the balance sheet. Therefore, the impugned order invoking the extended period was set aside, and the appeal was allowed.
Extended period of limitation of five years: Mere non-disclosure of receipts in the service tax return does not automatically mean there was an intent to evade payment of service tax. Suppression of facts has to be willful and with an intent to evade tax, as held by the Supreme Court. In this case, the department had already scrutinized the records earlier, and the show cause notice was based on entries available in the balance sheet. Therefore, the impugned order invoking the extended period was set aside, and the appeal was allowed.
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