Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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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