Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
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.