Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
CESTAT adjudicated a service tax dispute involving reimbursable expenses and business auxiliary services. The tribunal ruled in favor of the appellant, finding no valid basis for service tax levy on reimbursable expenses, consistent with SC precedent. The department's attempt to demand tax based on profit and loss account entries without demonstrating actual service consideration was rejected. Additionally, the tribunal found no evidence of intentional tax evasion, thereby invalidating extended limitation period and penalties. The appeal was allowed, effectively quashing the original tax demands and establishing that mere accounting entries cannot constitute taxable service under the Finance Act, 1994.
CESTAT adjudicated a service tax dispute involving reimbursable expenses and business auxiliary services. The tribunal ruled in favor of the appellant, finding no valid basis for service tax levy on reimbursable expenses, consistent with SC precedent. The department's attempt to demand tax based on profit and loss account entries without demonstrating actual service consideration was rejected. Additionally, the tribunal found no evidence of intentional tax evasion, thereby invalidating extended limitation period and penalties. The appeal was allowed, effectively quashing the original tax demands and establishing that mere accounting entries cannot constitute taxable service under the Finance Act, 1994.
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