Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
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.
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