Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Service tax on corporate guarantees arises only where consideration is received for rendering a taxable service. Corporate guarantees extended to associated enterprises without commission, fee or other consideration do not create taxable value merely because a notional amount can be computed using prevailing bank-guarantee rates. A precedent involving a corporate guarantee issued for paid consideration does not apply where the guarantee was provided without consideration. The demand for service tax on such guarantees was therefore dropped, and the Revenue's appeal was dismissed.
Service tax on corporate guarantees arises only where consideration is received for rendering a taxable service. Corporate guarantees extended to associated enterprises without commission, fee or other consideration do not create taxable value merely because a notional amount can be computed using prevailing bank-guarantee rates. A precedent involving a corporate guarantee issued for paid consideration does not apply where the guarantee was provided without consideration. The demand for service tax on such guarantees was therefore dropped, and the Revenue's appeal was dismissed.
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