Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Composite construction contracts were taxable, if at all, as works contract service because the disputed periods fell after that service was introduced and the activities were executed as works contracts. Demands raised under commercial or industrial construction service and construction of complex service were therefore unsustainable and were set aside. On valuation, the appellant was entitled to 67% abatement for works contracts, and the value of free-supplied materials had to be deducted from the taxable value. The Department's attempt to deny abatement on the full receipts, including VAT-paid goods, was rejected, and the resulting tax demands were held unsustainable.
Composite construction contracts were taxable, if at all, as works contract service because the disputed periods fell after that service was introduced and the activities were executed as works contracts. Demands raised under commercial or industrial construction service and construction of complex service were therefore unsustainable and were set aside. On valuation, the appellant was entitled to 67% abatement for works contracts, and the value of free-supplied materials had to be deducted from the taxable value. The Department's attempt to deny abatement on the full receipts, including VAT-paid goods, was rejected, and the resulting tax demands were held unsustainable.
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