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 article addresses invocation of the extended period of limitation for service tax demands where the taxpayer filed ST 3 returns and ITRs and performed self-assessment. It emphasises that show cause notices must specify the allegations and that extended limitation cannot be invoked where the appellant demonstrated bona fide belief in classifying services as exempt and consistently filed returns; the demand based on differences between ITR/Form 26AS and ST 3 without specifying service nature was held time barred and unsustainable.
The article addresses invocation of the extended period of limitation for service tax demands where the taxpayer filed ST 3 returns and ITRs and performed self-assessment. It emphasises that show cause notices must specify the allegations and that extended limitation cannot be invoked where the appellant demonstrated bona fide belief in classifying services as exempt and consistently filed returns; the demand based on differences between ITR/Form 26AS and ST 3 without specifying service nature was held time barred and unsustainable.
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