Captive power transfer pricing and non-resident export commission rules support deletion of adjustments and withholding disallowance in discussed proc...
Cooperative society deposits, member-interest TDS exemption and credit-facility deduction claims require verification through records and supporting e...
Customs jurisdiction over EPCG condition breaches survives export-obligation discharge certificates, requiring alleged fraud and misdeclaration to be ...
Contractual tolerance requires consideration; breach recoveries, qualifying public infrastructure services and road works escape service tax liability...
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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