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...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
Marketing and administrative support services rendered to an overseas entity were treated as export of services because the recipient was outside India, payment was received in convertible foreign exchange, and the arrangement was on a principal-to-principal basis; the place where work was performed in India was not determinative, so the service tax demand, interest and penalty were set aside. CENVAT credit denial for want of supporting documents also failed because the credit was disclosed in ST-3 returns and supporting invoices were produced during audit and refund proceedings, so the denial with interest and penalty was set aside. The extended period was unavailable in the absence of suppression, and the penalty for delayed registration survived only to the statutory ceiling.
Marketing and administrative support services rendered to an overseas entity were treated as export of services because the recipient was outside India, payment was received in convertible foreign exchange, and the arrangement was on a principal-to-principal basis; the place where work was performed in India was not determinative, so the service tax demand, interest and penalty were set aside. CENVAT credit denial for want of supporting documents also failed because the credit was disclosed in ST-3 returns and supporting invoices were produced during audit and refund proceedings, so the denial with interest and penalty was set aside. The extended period was unavailable in the absence of suppression, and the penalty for delayed registration survived only to the statutory ceiling.
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