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...
CESTAT adjudicated that the appellant provided taxable "renting of immovable property service" by leasing 22.68 acres of vacant land to the lessee. The tribunal found the revenue sharing arrangement was essentially a rental agreement, not a principal-to-principal contract. The additional lease amount calculated as 75% of receipts did not alter the rental nature of the transaction. Service tax demand, extended limitation period, and penalties were upheld as legally valid, with the appellant's deliberate suppression of lease income constituting willful tax evasion. The appeal was consequently dismissed.
CESTAT adjudicated that the appellant provided taxable "renting of immovable property service" by leasing 22.68 acres of vacant land to the lessee. The tribunal found the revenue sharing arrangement was essentially a rental agreement, not a principal-to-principal contract. The additional lease amount calculated as 75% of receipts did not alter the rental nature of the transaction. Service tax demand, extended limitation period, and penalties were upheld as legally valid, with the appellant's deliberate suppression of lease income constituting willful tax evasion. The appeal was consequently dismissed.
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TaxTMI 
TaxTMI 
of 4918 
