Penny-stock additions require transaction-specific evidence; general investigation material alone cannot establish undisclosed income or accommodation...
Transfer pricing comparability prioritises reliable external CUPs and foreign-currency LIBOR benchmarks for exports, borrowings and delayed receivable...
Section 153C satisfaction and seized electronic records sustained unexplained-investment addition, subject to proportionate ownership-share verificati...
The CESTAT allowed the appeal and set aside the impugned orders. It held that the appellant's delivery of courses under a recognized university leading to BCA/DCA/PGDCA constituted educational services exempt from service tax under the relevant notification; grants-in-aid received for centrally sponsored training were non-taxable; employer provident fund contributions could not be included in the gross value for manpower supply services; and demands framed as "Business Auxiliary/Business Support Service" were unsustainable where the SCN/adjudication failed to specify applicable sub-clauses. Further, invocation of the extended period of limitation was not maintainable on the facts. The appeals were allowed.
The CESTAT allowed the appeal and set aside the impugned orders. It held that the appellant's delivery of courses under a recognized university leading to BCA/DCA/PGDCA constituted educational services exempt from service tax under the relevant notification; grants-in-aid received for centrally sponsored training were non-taxable; employer provident fund contributions could not be included in the gross value for manpower supply services; and demands framed as "Business Auxiliary/Business Support Service" were unsustainable where the SCN/adjudication failed to specify applicable sub-clauses. Further, invocation of the extended period of limitation was not maintainable on the facts. The appeals were allowed.
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