Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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For periods before 14 May 2015, Section 67 of the Finance Act, 1994 confined the taxable value of Customs House Agent services to consideration charged for the taxable service. Rule 5 could not expand that value to include genuine reimbursements of third-party payments, including port, steamer-agent, container freight station, terminal-handling, demurrage and related charges incurred for clients. Recovery of those amounts from clients did not convert them into consideration for CHA services. The later inclusion of reimbursable expenditure in the valuation provision operated prospectively; related service-tax, interest and penalty demands therefore could not stand.
For periods before 14 May 2015, Section 67 of the Finance Act, 1994 confined the taxable value of Customs House Agent services to consideration charged for the taxable service. Rule 5 could not expand that value to include genuine reimbursements of third-party payments, including port, steamer-agent, container freight station, terminal-handling, demurrage and related charges incurred for clients. Recovery of those amounts from clients did not convert them into consideration for CHA services. The later inclusion of reimbursable expenditure in the valuation provision operated prospectively; related service-tax, interest and penalty demands therefore could not stand.
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