Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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