Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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