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...
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The AAAR determined that the appellant's services do not qualify for tax exemption under Notification No. 12/2017. The key issue centered on service supply conditions, specifically direct service provision to government entities. While the appellant provided manpower services to Webel Technology Limited for a government project, the services were not directly supplied to the government. WTL, as the intermediary, was responsible for payment, thereby disqualifying the services from exemption. Consequently, the appellant failed to meet the requisite conditions for tax exemption, rendering the service supply taxable under the prescribed notification.
The AAAR determined that the appellant's services do not qualify for tax exemption under Notification No. 12/2017. The key issue centered on service supply conditions, specifically direct service provision to government entities. While the appellant provided manpower services to Webel Technology Limited for a government project, the services were not directly supplied to the government. WTL, as the intermediary, was responsible for payment, thereby disqualifying the services from exemption. Consequently, the appellant failed to meet the requisite conditions for tax exemption, rendering the service supply taxable under the prescribed notification.
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