Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
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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