Intermediary service classification fails where overseas admission facilitation is supplied independently, preserving export treatment and small-provi...
Satellite transponder bandwidth is telecommunication, not Business Support Service; foreign non-telegraph providers triggered no service tax liability...
Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Transfer under section 127 was upheld because coordinated investigation is a valid administrative ground, and the assessee had no vested right to assessment at a particular place; the order was supported by notice, stated reasons, and consideration of the surrounding circumstances, so no mala fides or arbitrariness was shown. The notice under section 153A was quashed because the search record disclosed no incriminating material, the warrant alone was insufficient, and the foundational satisfaction for search-based proceedings had to exist on record. The reassessment proceedings were also held time barred, as the department was not restrained from completing assessment after notice under section 144 and the statutory period expired.
Transfer under section 127 was upheld because coordinated investigation is a valid administrative ground, and the assessee had no vested right to assessment at a particular place; the order was supported by notice, stated reasons, and consideration of the surrounding circumstances, so no mala fides or arbitrariness was shown. The notice under section 153A was quashed because the search record disclosed no incriminating material, the warrant alone was insufficient, and the foundational satisfaction for search-based proceedings had to exist on record. The reassessment proceedings were also held time barred, as the department was not restrained from completing assessment after notice under section 144 and the statutory period expired.
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