Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
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...
Intermediary service classification does not apply to loan origination, credit assessment, structuring, disbursement and loan-management activities performed by an Indian bank office for its Singapore head office where both form the same legal person. The arrangement lacks the required three distinct parties, identifiable main and ancillary supplies, and remuneration linked to the external lending service. The Indian office performs principal functions on its own account, while the head office alone enters into and makes final decisions on external commercial borrowing arrangements. The activities are therefore not liable to service tax as intermediary services, rendering the related demand and penalties unsustainable.
Intermediary service classification does not apply to loan origination, credit assessment, structuring, disbursement and loan-management activities performed by an Indian bank office for its Singapore head office where both form the same legal person. The arrangement lacks the required three distinct parties, identifiable main and ancillary supplies, and remuneration linked to the external lending service. The Indian office performs principal functions on its own account, while the head office alone enters into and makes final decisions on external commercial borrowing arrangements. The activities are therefore not liable to service tax as intermediary services, rendering the related demand and penalties unsustainable.
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