Condonation of Delay: directoral disputes and pending company proceedings can constitute reasonable cause, allowing a belated return to be treated as ...
Revisionary jurisdiction under section 263 upheld; faceless assessments subject to revision when AO fails requisite enquiries, remitted for fresh asse...
Limited scope of processing under section 143(1): enhancement without show cause is unsustainable; remand for residency, taxation and TDS verification...
The note addresses VCES eligibility where pre- and post-July 2012 liability arise from different legal questions: whether the appellant rendered an intellectual property service before July 2012 versus whether permitting Hallmarking/Assaying Centres to administer the BIS scheme for royalty constituted a 'service' after July 2012 under the post-July 2012 definition. It concludes that the issues are distinct, so the identical-issue proviso to the VCES does not bar acceptance of the later declaration; reliance on prior notices about intellectual property services did not preclude voluntary compliance for the separate charge based on the broader post-July 2012 service definition.
The note addresses VCES eligibility where pre- and post-July 2012 liability arise from different legal questions: whether the appellant rendered an intellectual property service before July 2012 versus whether permitting Hallmarking/Assaying Centres to administer the BIS scheme for royalty constituted a 'service' after July 2012 under the post-July 2012 definition. It concludes that the issues are distinct, so the identical-issue proviso to the VCES does not bar acceptance of the later declaration; reliance on prior notices about intellectual property services did not preclude voluntary compliance for the separate charge based on the broader post-July 2012 service definition.
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