MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Preventive suspension requires an immediate continuing threat and cannot become indefinite without inquiry, fresh evidence, or proportionate safeguard...
Consultancy and guidance supplied directly to a foreign client for its Indian business dealings do not constitute intermediary services where the consultant acts on its own account. Intermediary status requires three parties: a supplier of the principal service, its recipient, and a party performing the subsidiary role of arranging or facilitating that supply. Absence of a contractual relationship with Indian Railways and of any go-between function preserved the consultancy as a two-party service. The service therefore fell outside intermediary services, and the dropping of service tax, interest and penalty proceedings was upheld.
Consultancy and guidance supplied directly to a foreign client for its Indian business dealings do not constitute intermediary services where the consultant acts on its own account. Intermediary status requires three parties: a supplier of the principal service, its recipient, and a party performing the subsidiary role of arranging or facilitating that supply. Absence of a contractual relationship with Indian Railways and of any go-between function preserved the consultancy as a two-party service. The service therefore fell outside intermediary services, and the dropping of service tax, interest and penalty proceedings was upheld.
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