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...
HC quashed show cause notice due to unreasonable delay in adjudication spanning two decades. Department's internal CERA audit objection and conflicting views among Central Excise Officers led to prolonged inaction until January 2021. Court found petitioner had properly discharged service tax liability under works contract service per Section 65(95)(ZZZA) of Finance Act, 1994. Department's own Statement of Facts acknowledged disagreement with CERA audit findings. HC ordered refund of excess amounts deposited during investigation with 6% interest from payment date. Court affirmed petitioner's right to modify valuation method for service tax payment under Finance Act provisions.
HC quashed show cause notice due to unreasonable delay in adjudication spanning two decades. Department's internal CERA audit objection and conflicting views among Central Excise Officers led to prolonged inaction until January 2021. Court found petitioner had properly discharged service tax liability under works contract service per Section 65(95)(ZZZA) of Finance Act, 1994. Department's own Statement of Facts acknowledged disagreement with CERA audit findings. HC ordered refund of excess amounts deposited during investigation with 6% interest from payment date. Court affirmed petitioner's right to modify valuation method for service tax payment under Finance Act provisions.
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