Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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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