Donor-directed corpus contributions retain capital character despite exemption claims under section 10(23C)(vi), preventing their treatment as taxable...
Enhanced tax-audit threshold applies where banking records establish compliant non-cash receipts and payments, eliminating penalty exposure for audit ...
Transfer pricing consistency protects identical non-interest-bearing debenture terms from a later notional-interest adjustment without valid statutory...
Rectification of debatable deduction claims cannot reverse scrutiny-approved co-operative society interest income deductions as apparent record errors...
Cash-method accounting bars presumptive interest taxation, while unsupported securities and share-trading additions require reliable material and veri...
Section 7 admission requires established financial debt and default, not precise interest quantification, while post-suspension defaults remain action...
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The CESTAT held that the appellant's training programme, approved by the Ministry of Skill Development & Entrepreneurship and conducted as a partner of the National Skill Development Corporation, qualifies for exemption from service tax under Sl. No. 9A of Notification No. 25/2012-ST. The Tribunal found the programme falls within the scope of approved vocational education courses eligible for exemption under Section 66D(1)(iii) of the Finance Act, 1994, rendering further discussion on this ground unnecessary. Regarding limitation, the Department's prior knowledge and acknowledgement of the appellant's activities precluded invocation of the extended period for tax recovery, as no suppression of facts was established. Accordingly, the demand confirmed against the appellant was set aside on limitation grounds. The appeal was allowed, with no service tax liability confirmed against the appellant.
The CESTAT held that the appellant's training programme, approved by the Ministry of Skill Development & Entrepreneurship and conducted as a partner of the National Skill Development Corporation, qualifies for exemption from service tax under Sl. No. 9A of Notification No. 25/2012-ST. The Tribunal found the programme falls within the scope of approved vocational education courses eligible for exemption under Section 66D(1)(iii) of the Finance Act, 1994, rendering further discussion on this ground unnecessary. Regarding limitation, the Department's prior knowledge and acknowledgement of the appellant's activities precluded invocation of the extended period for tax recovery, as no suppression of facts was established. Accordingly, the demand confirmed against the appellant was set aside on limitation grounds. The appeal was allowed, with no service tax liability confirmed against the appellant.
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