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...
The CESTAT held that the appellant's services could not be classified as intermediary services for the period July 2012 to March 2014. As per Rule 3 of the Place of Provision of Services Rules, the place of provision was the location of the service recipient outside India. Since payment was received in convertible foreign exchange, the services qualified as export of services u/r 6 of the Service Tax Rules, 1994. Consequently, no service tax was leviable, and the demand was set aside. The appeal was allowed.
The CESTAT held that the appellant's services could not be classified as intermediary services for the period July 2012 to March 2014. As per Rule 3 of the Place of Provision of Services Rules, the place of provision was the location of the service recipient outside India. Since payment was received in convertible foreign exchange, the services qualified as export of services u/r 6 of the Service Tax Rules, 1994. Consequently, no service tax was leviable, and the demand was set aside. The appeal was allowed.
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TaxTMI 
TaxTMI 
of 4921 
