Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
The text addresses whether commission receipts relating to alleged sale/export of Indian raw cotton qualify as a non-taxable transfer of immovable property or as taxable services and whether exemption under Notification No.13/2003-ST applies; the documents were held insufficient to prove commission receipts as genuine sales commissions, resulting in denial of exemption. It also examines invocation of the extended assessment period due to undisclosed commission income and audit-detected mismatches, finding suppression with intent to evade service tax and upholding extended-period assessment and confirmed service tax demand for 2010-11 and 2011-12.
The text addresses whether commission receipts relating to alleged sale/export of Indian raw cotton qualify as a non-taxable transfer of immovable property or as taxable services and whether exemption under Notification No.13/2003-ST applies; the documents were held insufficient to prove commission receipts as genuine sales commissions, resulting in denial of exemption. It also examines invocation of the extended assessment period due to undisclosed commission income and audit-detected mismatches, finding suppression with intent to evade service tax and upholding extended-period assessment and confirmed service tax demand for 2010-11 and 2011-12.
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