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...
Commission paid to a foreign director for marketing and sourcing export orders was held taxable under reverse charge because the director supplied services from outside India, the recipient was in India, and the place of supply under Section 13(2) was India, making it an import of services. Commission paid to foreign marketing agents was held not taxable because they were treated as intermediary services and, under Section 13(8), the place of supply was outside India, so the import of services condition failed. Charges paid to foreign clearing and forwarding agents for arrival, customs clearance and terminal handling services rendered abroad were held taxable under reverse charge as import of services.
Commission paid to a foreign director for marketing and sourcing export orders was held taxable under reverse charge because the director supplied services from outside India, the recipient was in India, and the place of supply under Section 13(2) was India, making it an import of services. Commission paid to foreign marketing agents was held not taxable because they were treated as intermediary services and, under Section 13(8), the place of supply was outside India, so the import of services condition failed. Charges paid to foreign clearing and forwarding agents for arrival, customs clearance and terminal handling services rendered abroad were held taxable under reverse charge as import of services.
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