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...
Service tax liability of a mutual fund sub-distributor was held to arise from the status of the service provider: the reverse charge notification applied to services provided by a distributor to the mutual fund, not to a sub-distributor rendering Business Auxiliary Service to the distributor. Receipts from the cooperative bank were also treated as taxable consideration because wages alone did not prove an employer-employee relationship and no employment contract was produced. The Tribunal further upheld extended limitation and penalty under section 78, finding no material basis for bona fide belief or delayed registration. Penalties under sections 77(1)(c) and 77(2) were sustained for failure to furnish information and file ST-3 returns.
Service tax liability of a mutual fund sub-distributor was held to arise from the status of the service provider: the reverse charge notification applied to services provided by a distributor to the mutual fund, not to a sub-distributor rendering Business Auxiliary Service to the distributor. Receipts from the cooperative bank were also treated as taxable consideration because wages alone did not prove an employer-employee relationship and no employment contract was produced. The Tribunal further upheld extended limitation and penalty under section 78, finding no material basis for bona fide belief or delayed registration. Penalties under sections 77(1)(c) and 77(2) were sustained for failure to furnish information and file ST-3 returns.
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