Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Core procurement services rendered by a foreign group procurement hub to an Indian entity were held not to be intermediary services, because the arrangement satisfied neither the statutory two-supply character of an intermediary nor a mere facilitation role. The Tribunal treated the foreign entity as an independent contractor acting on its own account under a principal-to-principal arrangement, so the services were an import of services with place of supply in India and were taxable there, defeating the refund claim. It also held that a refund application under the GST refund framework cannot be rejected solely as an afterthought merely because tax was first paid and non-taxability was later asserted.
Core procurement services rendered by a foreign group procurement hub to an Indian entity were held not to be intermediary services, because the arrangement satisfied neither the statutory two-supply character of an intermediary nor a mere facilitation role. The Tribunal treated the foreign entity as an independent contractor acting on its own account under a principal-to-principal arrangement, so the services were an import of services with place of supply in India and were taxable there, defeating the refund claim. It also held that a refund application under the GST refund framework cannot be rejected solely as an afterthought merely because tax was first paid and non-taxability was later asserted.
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