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...
Painting and end-to-end execution services for residential, commercial and industrial premises were held not to constitute management, maintenance or repair service. The Tribunal noted that the services, on the admitted facts, were more appropriately covered by construction-related activity and that in the appellant's own case for a prior period the original authority had already treated the work as works contract service. The demand raised under management, maintenance or repair service was therefore unsustainable, and the activity was held to be correctly classifiable under works contract service. The impugned order was set aside and consequential relief followed in accordance with law.
Painting and end-to-end execution services for residential, commercial and industrial premises were held not to constitute management, maintenance or repair service. The Tribunal noted that the services, on the admitted facts, were more appropriately covered by construction-related activity and that in the appellant's own case for a prior period the original authority had already treated the work as works contract service. The demand raised under management, maintenance or repair service was therefore unsustainable, and the activity was held to be correctly classifiable under works contract service. The impugned order was set aside and consequential relief followed in accordance with law.
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