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...
A partner's payment of service tax using the partner's registration may be adjusted against the firm's liability because a partner is not a separate legal entity; the adjustment is allowed. The appellant's liability as subcontractor for services including transportation of goods is sustained, but supporting documents submitted must be examined. The impugned rejection of abatement/reconciliation is remanded for fresh consideration and verification of invoices, payment documents and work orders. The authority is directed to recompute service tax on works contract and transportation services after giving the appellant opportunity to produce relevant records.
A partner's payment of service tax using the partner's registration may be adjusted against the firm's liability because a partner is not a separate legal entity; the adjustment is allowed. The appellant's liability as subcontractor for services including transportation of goods is sustained, but supporting documents submitted must be examined. The impugned rejection of abatement/reconciliation is remanded for fresh consideration and verification of invoices, payment documents and work orders. The authority is directed to recompute service tax on works contract and transportation services after giving the appellant opportunity to produce relevant records.
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