Purposive interpretation of residential house exemption: unregistered purchase agreement alone does not defeat relief, but investment must be verified...
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Imported technical know-how from a foreign entity was not taxable as intellectual property service on reverse charge because the alleged intellectual property was not shown to be recognised under Indian law; the demand was therefore unsustainable and dropped. A composite engineering development arrangement was not taxable as consulting engineering service because the agreement involved joint development, design, detailing, prototype work and production support rather than advice, consultancy or technical assistance simpliciter; the demand was set aside. As both demands failed, issues of limitation, revenue neutrality, interest and penalty did not survive.
Imported technical know-how from a foreign entity was not taxable as intellectual property service on reverse charge because the alleged intellectual property was not shown to be recognised under Indian law; the demand was therefore unsustainable and dropped. A composite engineering development arrangement was not taxable as consulting engineering service because the agreement involved joint development, design, detailing, prototype work and production support rather than advice, consultancy or technical assistance simpliciter; the demand was set aside. As both demands failed, issues of limitation, revenue neutrality, interest and penalty did not survive.
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