Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Government grants-in-aid do not constitute consideration for Business Exhibition Service where agreements impose only utilisation and accounting conditions, without an obligation to provide services, invoices, or quid pro quo. As reimbursement of specified expenditure, they fall outside taxable value, which is confined to amounts charged for taxable services; the related demand was set aside. Extended limitation cannot apply where grants and expenditure were recorded, the taxpayer paid tax on other services, and a bona fide belief of non-taxability negated suppression with intent to evade. Reverse-charge demands were likewise time-barred because recorded liabilities were revenue neutral through available Cenvat credit.
Government grants-in-aid do not constitute consideration for Business Exhibition Service where agreements impose only utilisation and accounting conditions, without an obligation to provide services, invoices, or quid pro quo. As reimbursement of specified expenditure, they fall outside taxable value, which is confined to amounts charged for taxable services; the related demand was set aside. Extended limitation cannot apply where grants and expenditure were recorded, the taxpayer paid tax on other services, and a bona fide belief of non-taxability negated suppression with intent to evade. Reverse-charge demands were likewise time-barred because recorded liabilities were revenue neutral through available Cenvat credit.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
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