Trademark depreciation and section 14A adjustments: ITAT applies consistency, independent book-profit computation, and no disallowance without exempt ...
Rebuttable search presumptions and corroboration standards shaped deletion of unsubstantiated additions, while rental income and limited profit estima...
Freight forwarding on a principal-to-principal basis was treated as an independent transportation arrangement, not a mere intermediary or support activity. The Tribunal accepted that where the forwarder negotiates freight with carriers and customers, procures cargo space on its own account, and bears the legal responsibility and risks of transportation, the amounts recovered from customers for ocean freight and air freight cannot form part of the assessable value for business support service. On that basis, the service tax demand on those freight recoveries was held unsustainable and the impugned order was set aside.
Freight forwarding on a principal-to-principal basis was treated as an independent transportation arrangement, not a mere intermediary or support activity. The Tribunal accepted that where the forwarder negotiates freight with carriers and customers, procures cargo space on its own account, and bears the legal responsibility and risks of transportation, the amounts recovered from customers for ocean freight and air freight cannot form part of the assessable value for business support service. On that basis, the service tax demand on those freight recoveries was held unsustainable and the impugned order was set aside.
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