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...
CESTAT held that the extended period of limitation was wrongly invoked in the first show cause notice. The service tax demand on amounts received from foreign counterparts under reverse charge mechanism is upheld within the normal limitation period. The appellant's incorrect understanding of tax law was deemed a reasonable cause. All penalties were set aside under section 80. The appeal was partially allowed, with the matter remanded to the Commissioner for calculating and appropriating tax and interest payments already made.
CESTAT held that the extended period of limitation was wrongly invoked in the first show cause notice. The service tax demand on amounts received from foreign counterparts under reverse charge mechanism is upheld within the normal limitation period. The appellant's incorrect understanding of tax law was deemed a reasonable cause. All penalties were set aside under section 80. The appeal was partially allowed, with the matter remanded to the Commissioner for calculating and appropriating tax and interest payments already made.
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TaxTMI 
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