Permanent Establishment and Business Connection: foreign consultancy receipts not attributable where no fixed base or corporate veil piercing establis...
Limitation period commencement and procedural inquiry rules: identity-based limitation upheld; complaints by authorised public servants need not attra...
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.
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