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...
Levy of Service Tax - Incentive received - (i) the air travel agent is promoting its own business and is not promoting the business of the airlines; - (ii) the air travel agent is not promoting the business of the CRS Companies; - (iii) in any view of the matter, the classification of the service would fall under “air travel agent” service and not “BAS” in terms of the provisions of section 65A of the Finance Act; and - (iv) the incentives paid for achieving the targets are not leviable to service tax. - AT
Levy of Service Tax - Incentive received - (i) the air travel agent is promoting its own business and is not promoting the business of the airlines; - (ii) the air travel agent is not promoting the business of the CRS Companies; - (iii) in any view of the matter, the classification of the service would fall under “air travel agent” service and not “BAS” in terms of the provisions of section 65A of the Finance Act; and - (iv) the incentives paid for achieving the targets are not leviable to service tax. - AT
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