Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
Deductions made from sub-contractors' bills were held to be consideration for taxable business support services, not mere reimbursement of CSR or labour welfare . The Tribunal found that the appellant produced no material to show that the recoveries represented actual expenditure incurred on behalf of the contractors' workmen, and the uniform percentage deduction from bill value indicated a quid pro quo for administrative and operational support. The plea of double taxation failed because the contractors' construction service and the appellant's separate support service were distinct taxable activities. The extended period of limitation was also upheld, as the recoveries were not disclosed in returns and the change in nomenclature after audit supported suppression of facts with intent to evade tax.
Deductions made from sub-contractors' bills were held to be consideration for taxable business support services, not mere reimbursement of CSR or labour welfare . The Tribunal found that the appellant produced no material to show that the recoveries represented actual expenditure incurred on behalf of the contractors' workmen, and the uniform percentage deduction from bill value indicated a quid pro quo for administrative and operational support. The plea of double taxation failed because the contractors' construction service and the appellant's separate support service were distinct taxable activities. The extended period of limitation was also upheld, as the recoveries were not disclosed in returns and the change in nomenclature after audit supported suppression of facts with intent to evade tax.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
