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...
Tax treatment of internet advertising and sale of IT goods: appellant sold online ad space and operated e-commerce sites, believed these services fell under the negative list and therefore did not register or pay service tax; electronic invoices were produced. Because the appellant later disclosed the full nature of activities when seeking registration and had a bona fide belief in non-taxability, the extended limitation period based on alleged suppression was held inapplicable and the retrospective demand was set aside; electronic invoices treated as valid evidence; appeal allowed.
Tax treatment of internet advertising and sale of IT goods: appellant sold online ad space and operated e-commerce sites, believed these services fell under the negative list and therefore did not register or pay service tax; electronic invoices were produced. Because the appellant later disclosed the full nature of activities when seeking registration and had a bona fide belief in non-taxability, the extended limitation period based on alleged suppression was held inapplicable and the retrospective demand was set aside; electronic invoices treated as valid evidence; appeal allowed.
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