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...
A registered cooperative society that confined lending and deposit-related activities to its own members was held not liable to service tax under Banking and Other Financial Services. Applying the principle of mutuality, the Tribunal found that services rendered by such a society to its members do not constitute taxable services provided by one person to another. The contrary view treating the society as a commercial concern was unsustainable, and the demand of service tax and related penalties based on member-based services were set aside.
A registered cooperative society that confined lending and deposit-related activities to its own members was held not liable to service tax under Banking and Other Financial Services. Applying the principle of mutuality, the Tribunal found that services rendered by such a society to its members do not constitute taxable services provided by one person to another. The contrary view treating the society as a commercial concern was unsustainable, and the demand of service tax and related penalties based on member-based services were set aside.
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