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...
The CESTAT held that the extended period of limitation invoked for levying service tax was unsustainable as there was no wilful suppression of facts by the appellant. The demands of Rs.1,01,6,502/- under 'sponsorship' services, Rs.13,30,558/- on inter-company expenses, and Rs.20,371/- as interest were set aside. For renting services, the demand of Rs.2,45,58,483/- was set aside, and the appellant was directed to produce evidence for the remaining Rs.34,29,130/-. The demands of Rs.73,00,732/- for import of services and Rs.2,80,40,921/- for software licenses were remanded for de-novo adjudication to determine the appellant's role and liabilities. The penalties were also set aside. The appeal was disposed of accordingly.
The CESTAT held that the extended period of limitation invoked for levying service tax was unsustainable as there was no wilful suppression of facts by the appellant. The demands of Rs.1,01,6,502/- under 'sponsorship' services, Rs.13,30,558/- on inter-company expenses, and Rs.20,371/- as interest were set aside. For renting services, the demand of Rs.2,45,58,483/- was set aside, and the appellant was directed to produce evidence for the remaining Rs.34,29,130/-. The demands of Rs.73,00,732/- for import of services and Rs.2,80,40,921/- for software licenses were remanded for de-novo adjudication to determine the appellant's role and liabilities. The penalties were also set aside. The appeal was disposed of accordingly.
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