Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Club and Association Service - The ‘club or association’ was earlier defined under section 65(25a) and 65(25aa) to mean ‘any person’ or ‘body or persons’ providing service. The expression ‘body of persons’ cannot be possibly include persons who are incorporated entities, as such entities have been expressly excluded under sections 65(25a)(i) and 65(25aa)(i) as ‘any body established or constituted by or under any law for the time being in force’. - It is not in dispute that in the present case the respondent has been incorporated under the provisions of the Societies Registration Act. - Not liable to service tax - AT
Club and Association Service - The ‘club or association’ was earlier defined under section 65(25a) and 65(25aa) to mean ‘any person’ or ‘body or persons’ providing service. The expression ‘body of persons’ cannot be possibly include persons who are incorporated entities, as such entities have been expressly excluded under sections 65(25a)(i) and 65(25aa)(i) as ‘any body established or constituted by or under any law for the time being in force’. - It is not in dispute that in the present case the respondent has been incorporated under the provisions of the Societies Registration Act. - Not liable to service tax - AT
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