Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
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...
Reduction of Credit to claim refund u/Rule 5 - The only amount which can be reduced is the amount which is reversed in terms of Sub-rule (5C) of Rule 3 during the relevant period. Therefore no amount which was utilized for payment of service tax in respect of domestic provision of service from cenvat amount is required to be reversed as per formula. - AT
Reduction of Credit to claim refund u/Rule 5 - The only amount which can be reduced is the amount which is reversed in terms of Sub-rule (5C) of Rule 3 during the relevant period. Therefore no amount which was utilized for payment of service tax in respect of domestic provision of service from cenvat amount is required to be reversed as per formula. - AT
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
