Department only when the data
from Income Tax Authorities was shared, which justifies the invocation
of the extended limitation period of five years under ... which came to the knowledge of the Department only after data
shared by Income Tax Department, justifies penalties, as supported by
judicial precedents like Madras
principal-to-principal basis and are
in the nature of sharing of revenue, therefore there is no service
being provided from one party to another ... upon by the
appellant regarding the revenue-sharing arrangement clearly
held that if there is a revenue-sharing arrangement on
principal-to-principal basis
were not invocable and
that the demand having been issued beyond the five years
period, I find that the said data sharing between the CBIC
Ms Tsi Yatra Pvt Ltd vs Principal Commissioner Central Excise ... on 20 December, 2024
CUSTOMS
owner and has not discharged service tax on
the Owner's Share; therefore, tax is leviable on the
value of the flats allotted ... invocable due to
suppression and non‑disclosure in the returns filed.
8.8 The question whether service tax is exigible on
the Owner's Share
sale of
landowners share of constructed property as exempted service and had
proposed to demand proportionate credit from the Appellant. Hence
invocation of extended period
Business or Commerce‟. He
further submits that as per the agreement, revenue sharing is done
where the hospital retained a portion of fees collected from ... upon by the appellant
regarding the revenue-sharing arrangement clearly held that if there
is a revenue-sharing arrangement on principal-to-principal basis
that
the invocation of Rule 8 is incorrect, however he is empowered to decide
the issue as an adjudicating authority. The 100% shares
that
the invocation of Rule 8 is incorrect, however he is empowered to decide
the issue as an adjudicating authority. The 100% shares
that royalty paid in exchange was in the form of a share of profit and not a payment for any service received. In Navinon ... attract service tax. Arguments were advanced with case law against invocation of the larger period and imposition of penalty.
5. Ld. JCDR reiterates the findings
