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    <title>Tax demand quashed for pure-agent reimbursements and time-barred claims; reverse-charge legal fees set aside; late fee upheld</title>
    <link>https://www.taxtmi.com/highlights?id=93523</link>
    <description>CESTAT partly allowed the appeal. The Tribunal held that a demand founded solely on comparison of Form 26AS/IT returns with ST-3 without further inquiry was unsustainable; amounts shown as reimbursements under contracts where the appellant acted as a &quot;pure agent&quot; on actuals are not includible in taxable consideration, so the demand on such reimbursements was set aside. Extended-period demands were time-barred and therefore quashed. Confirmed demands under &quot;Legal Charges&quot; paid under reverse-charge were set aside on merits and for time-bar, given evidence of consultants&#039; tax payment and the likelihood of input-credit neutralization. However, a late-filing fee imposed on the appellant was upheld.</description>
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    <pubDate>Sat, 25 Oct 2025 09:00:56 +0530</pubDate>
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      <title>Tax demand quashed for pure-agent reimbursements and time-barred claims; reverse-charge legal fees set aside; late fee upheld</title>
      <link>https://www.taxtmi.com/highlights?id=93523</link>
      <description>CESTAT partly allowed the appeal. The Tribunal held that a demand founded solely on comparison of Form 26AS/IT returns with ST-3 without further inquiry was unsustainable; amounts shown as reimbursements under contracts where the appellant acted as a &quot;pure agent&quot; on actuals are not includible in taxable consideration, so the demand on such reimbursements was set aside. Extended-period demands were time-barred and therefore quashed. Confirmed demands under &quot;Legal Charges&quot; paid under reverse-charge were set aside on merits and for time-bar, given evidence of consultants&#039; tax payment and the likelihood of input-credit neutralization. However, a late-filing fee imposed on the appellant was upheld.</description>
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      <pubDate>Sat, 25 Oct 2025 09:00:56 +0530</pubDate>
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