Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Emergency care and life-support courses were treated as structured skill-based training, not public awareness of preventive health or charitable activity under Notification No. 12/2017. The Authority held that training delivered to identifiable participants for consideration, with evaluation, certification and renewal of certificates, did not qualify for exemption under Entry 1, and the same reasoning applied to renewal fees. It also found that the provider was not an educational institution for Entry 66 purposes because the courses were not part of a recognised curriculum or approved vocational education. The services were classified as commercial training and coaching services under SAC 999293 and held taxable at 18%.
Emergency care and life-support courses were treated as structured skill-based training, not public awareness of preventive health or charitable activity under Notification No. 12/2017. The Authority held that training delivered to identifiable participants for consideration, with evaluation, certification and renewal of certificates, did not qualify for exemption under Entry 1, and the same reasoning applied to renewal fees. It also found that the provider was not an educational institution for Entry 66 purposes because the courses were not part of a recognised curriculum or approved vocational education. The services were classified as commercial training and coaching services under SAC 999293 and held taxable at 18%.
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