Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Reverse charge demands on foreign services were struck down because the notices did not identify the applicable limb of the 2006 Rules, did not specify the taxable service or quantify consideration service-wise, and relied only on consolidated profit and loss figures. The TDS remitted separately to the Income Tax Department for architect services was not part of the taxable value, as service tax had been paid on the gross service charge. Credit on renting of leased premises was allowed because the premises was used as a business godown and for output services, and credit is not confined to registered premises. Extended limitation was unavailable since the dispute arose from audit, suppression was not proved, and the earlier notice could not justify repeated invocation on the same facts.
Reverse charge demands on foreign services were struck down because the notices did not identify the applicable limb of the 2006 Rules, did not specify the taxable service or quantify consideration service-wise, and relied only on consolidated profit and loss figures. The TDS remitted separately to the Income Tax Department for architect services was not part of the taxable value, as service tax had been paid on the gross service charge. Credit on renting of leased premises was allowed because the premises was used as a business godown and for output services, and credit is not confined to registered premises. Extended limitation was unavailable since the dispute arose from audit, suppression was not proved, and the earlier notice could not justify repeated invocation on the same facts.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4821 
Join Channel 
