Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Wall rent paid for sites used to display advertisements was held includible in the taxable value of advertising agency service because it was an intrinsic and inseparable part of the service, and the assessee failed to establish a valid pure agent arrangement or direct contractual link between clients and wall owners. By contrast, the value of printed flex material supplied through a separately registered concern, separately invoiced and taxed as goods, was held not includible under the service tax valuation rules or Notification No. 12/2003-ST. The extended limitation period was rejected because suppression or wilful misstatement was not proved in an audit-based notice, and penalties were deleted as the dispute was interpretational.
Wall rent paid for sites used to display advertisements was held includible in the taxable value of advertising agency service because it was an intrinsic and inseparable part of the service, and the assessee failed to establish a valid pure agent arrangement or direct contractual link between clients and wall owners. By contrast, the value of printed flex material supplied through a separately registered concern, separately invoiced and taxed as goods, was held not includible under the service tax valuation rules or Notification No. 12/2003-ST. The extended limitation period was rejected because suppression or wilful misstatement was not proved in an audit-based notice, and penalties were deleted as the dispute was interpretational.
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