https://www.taxtmi.com/caselaws?id=439327 Commission paid to a foreign holding company for a corporate guarantee arrangement was held taxable as a service after 01.07.2012 under section 66B of the Finance Act, 1994 and the reverse charge framework in Notification No. 30/2012-ST. The taxability remained unaffected by the classification dispute. However, the extended period of limitation was not available for 2013-14 because wilful suppression was not established, the transaction was revenue neutral, and penalty was therefore unsustainable. For 2014-15, the demand fell within the normal period and the matter was remanded for quantification of tax and interest, after adjusting the amount already deposited. en-us Mon, 19 Jun 2023 00:00:00 +0530 Thu, 22 Jun 2023 09:05:24 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=439327 Commission paid to a foreign holding company for a corporate guarantee arrangement was held taxable as a service after 01.07.2012 under section 66B of the Finance Act, 1994 and the reverse charge framework in Notification No. 30/2012-ST. The taxability remained unaffected by the classification dispute. However, the extended period of limitation was not available for 2013-14 because wilful suppression was not established, the transaction was revenue neutral, and penalty was therefore unsustainable. For 2014-15, the demand fell within the normal period and the matter was remanded for quantification of tax and interest, after adjusting the amount already deposited. Case-Laws Service Tax Mon, 19 Jun 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=439327