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...
Taxability of domain registration and web hosting services is affirmed by classifying such activities within information technology software/online information and database access or retrieval services, making sale of domain registration, hosting space, hosting backups and renewals leviable to service tax; export of services remains excluded and not taxable. Invocation of the extended period of limitation was upheld due to non-registration and non-filing of returns, supporting confirmation of escaped tax and imposition of demand. Penalty and interest quantification were not finally determined and the matter is remanded to the original adjudicating authority for reasoned computation and assessment.
Taxability of domain registration and web hosting services is affirmed by classifying such activities within information technology software/online information and database access or retrieval services, making sale of domain registration, hosting space, hosting backups and renewals leviable to service tax; export of services remains excluded and not taxable. Invocation of the extended period of limitation was upheld due to non-registration and non-filing of returns, supporting confirmation of escaped tax and imposition of demand. Penalty and interest quantification were not finally determined and the matter is remanded to the original adjudicating authority for reasoned computation and assessment.
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