Regulatory consolidation for investment advisers: SEBI issues master circular consolidating guidance and prescribing compliance, reporting, fees and s...
Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Demand on renting of immovable property was held partly time-barred as extended limitation was invoked without proving suppression with intent to evade; the portion beyond normal period was set aside, while the normal-period tax was confirmed and no penalty was imposed since tax and interest were already paid. Demand on management/business consultancy under RCM was rejected for want of evidence linking foreign currency expenses to taxable services and as revenue-neutral; the entire demand (raised only under extended period) was set aside. Commission paid for selling tea abroad was held exempt under the relevant notification without territorial restriction; demand was set aside. Royalty/licence fee and other remittance-related demands were set aside for limitation and lack of findings/evidence. All penalties were quashed under Section 73(3). - CESTAT
Demand on renting of immovable property was held partly time-barred as extended limitation was invoked without proving suppression with intent to evade; the portion beyond normal period was set aside, while the normal-period tax was confirmed and no penalty was imposed since tax and interest were already paid. Demand on management/business consultancy under RCM was rejected for want of evidence linking foreign currency expenses to taxable services and as revenue-neutral; the entire demand (raised only under extended period) was set aside. Commission paid for selling tea abroad was held exempt under the relevant notification without territorial restriction; demand was set aside. Royalty/licence fee and other remittance-related demands were set aside for limitation and lack of findings/evidence. All penalties were quashed under Section 73(3). - CESTAT
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