Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
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...
High seas sale transactions are characterised predominantly as sales of imported goods where the buyer pays a composite invoiced amount including letter of credit charges and other seller-incurred costs. A trader that neither issues a letter of credit nor provides a payment guarantee does not render banking or financial services merely by recovering its letter of credit costs from the buyer. Those charges form part of the sale consideration, and transfer of title in goods by sale falls outside the definition of service under the post-negative-list regime. Because obtaining the letter of credit is incidental to executing the sale, the composite price cannot be split to tax the embedded charges separately as a service.
High seas sale transactions are characterised predominantly as sales of imported goods where the buyer pays a composite invoiced amount including letter of credit charges and other seller-incurred costs. A trader that neither issues a letter of credit nor provides a payment guarantee does not render banking or financial services merely by recovering its letter of credit costs from the buyer. Those charges form part of the sale consideration, and transfer of title in goods by sale falls outside the definition of service under the post-negative-list regime. Because obtaining the letter of credit is incidental to executing the sale, the composite price cannot be split to tax the embedded charges separately as a service.
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