Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Packaged information technology software copied onto a medium and marketed is described as possessing the attributes of goods, making its transfer a deemed sale excluded from taxable service. The text states that inability to meet the conditions of Notification No. 11/2016-ST does not convert such a sale into a taxable service; accordingly, the related service tax demand, interest and penalty were deleted. It separately states that late fee for failure to file prescribed periodic service tax returns after registration remained payable, and the appeal was partly allowed.
Packaged information technology software copied onto a medium and marketed is described as possessing the attributes of goods, making its transfer a deemed sale excluded from taxable service. The text states that inability to meet the conditions of Notification No. 11/2016-ST does not convert such a sale into a taxable service; accordingly, the related service tax demand, interest and penalty were deleted. It separately states that late fee for failure to file prescribed periodic service tax returns after registration remained payable, and the appeal was partly allowed.
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