Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
Invocation of the extended limitation proviso was examined on whether bona fide belief about Notification No.30/2012 and allocation of tax liability to service recipients supplied a plausible basis for non-payment; the analysis applied authorities requiring fraud, collusion, wilful misstatement or suppression of facts to invoke the extended five-year period. Absent documentary proof of transfer of possession or specific averments proving mala fide conduct or positive acts of suppression, mere non-payment or incomplete returns did not satisfy the threshold, and the extended-period demand was held unsustainable.
Invocation of the extended limitation proviso was examined on whether bona fide belief about Notification No.30/2012 and allocation of tax liability to service recipients supplied a plausible basis for non-payment; the analysis applied authorities requiring fraud, collusion, wilful misstatement or suppression of facts to invoke the extended five-year period. Absent documentary proof of transfer of possession or specific averments proving mala fide conduct or positive acts of suppression, mere non-payment or incomplete returns did not satisfy the threshold, and the extended-period demand was held unsustainable.
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