Writ relief against show cause notices is available where jurisdiction is absent and concluded advance rulings cannot be reopened without fresh fraud ...
Section 80P business attribution: ITAT allows deduction on investment interest and ancillary receipts, but excludes staff-loan and other non-eligible ...
The note addresses tax treatment of manpower supply services, applying the Service Tax Rules definition of 'supply of manpower' and the reverse charge principle that places service tax liability on the recipient where manpower is supplied by an individual or partnership to a body corporate; the liability for services to RailTel therefore rests with the recipient. It finds invocation of the extended limitation period unsustainable where the issue was already known from an earlier audit, and it sets aside demands made on that basis. It also concludes that penalty for suppression is unwarranted where the supplier declared services and no corroborative evidence of evasion exists.
The note addresses tax treatment of manpower supply services, applying the Service Tax Rules definition of 'supply of manpower' and the reverse charge principle that places service tax liability on the recipient where manpower is supplied by an individual or partnership to a body corporate; the liability for services to RailTel therefore rests with the recipient. It finds invocation of the extended limitation period unsustainable where the issue was already known from an earlier audit, and it sets aside demands made on that basis. It also concludes that penalty for suppression is unwarranted where the supplier declared services and no corroborative evidence of evasion exists.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
