Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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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