Bona fide disclosure requirements govern under-reporting penalties, and post-penalty immunity applications cannot secure available statutory protectio...
Certificate-of-origin verification procedure governs preferential customs benefits; denial without retroactive verification was set aside with consequ...
Disciplinary Committee jurisdiction and mandatory investigation requirements invalidated cancellation of an insolvency professional's registration and...
Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
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Intermediary-service classification turns on whether a supplier arranges or facilitates a distinct main supply between two other persons and acts as an agent, broker or similar person. Services supplied on the provider's own account are excluded. Marketing, sales support, technical, manufacturing, administrative and customer-support services provided to overseas group entities under cost-plus arrangements are described as principal-to-principal supplies where the provider cannot conclude sales contracts, does not negotiate sales, and remuneration is not linked to goods sales. On that analysis, such services are treated as export of services rather than intermediary services, with demands and penalties set aside.
Intermediary-service classification turns on whether a supplier arranges or facilitates a distinct main supply between two other persons and acts as an agent, broker or similar person. Services supplied on the provider's own account are excluded. Marketing, sales support, technical, manufacturing, administrative and customer-support services provided to overseas group entities under cost-plus arrangements are described as principal-to-principal supplies where the provider cannot conclude sales contracts, does not negotiate sales, and remuneration is not linked to goods sales. On that analysis, such services are treated as export of services rather than intermediary services, with demands and penalties set aside.
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