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...
Merchant discount rate in credit-card transactions is a composite charge comprising the acquiring bank fee, issuing bank interchange fee and platform fee. Where service tax has been paid on the entire merchant discount rate, subsequent allocation of the interchange fee to the issuing bank does not create a separately taxable service. A further levy on that retained interchange fee would amount to double taxation, particularly where there is no revenue loss. Service-tax demands on interchange fee, along with consequential interest and penalties, were therefore unsustainable and set aside.
Merchant discount rate in credit-card transactions is a composite charge comprising the acquiring bank fee, issuing bank interchange fee and platform fee. Where service tax has been paid on the entire merchant discount rate, subsequent allocation of the interchange fee to the issuing bank does not create a separately taxable service. A further levy on that retained interchange fee would amount to double taxation, particularly where there is no revenue loss. Service-tax demands on interchange fee, along with consequential interest and penalties, were therefore unsustainable and set aside.
Note: It is a system-generated summary and is for quick reference only.
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