Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Demand of service tax on roaming charges - The appellant, as a licencee of the domestic telecommunication regulatory regime, is not conferred with empowerment to operate in a foreign territory and can neither, conceivably, offer such service independent of the overseas entity nor avail of the equipment of overseas operator for rendering ‘telecommunication service’ to its subscribers. The activity, therefore, lies outside the ambit of ‘support service of business or commerce’ which is the ‘taxable service’ sought to be fastened on the appellant as ‘deemed provider’ under section 66A - AT
Demand of service tax on roaming charges - The appellant, as a licencee of the domestic telecommunication regulatory regime, is not conferred with empowerment to operate in a foreign territory and can neither, conceivably, offer such service independent of the overseas entity nor avail of the equipment of overseas operator for rendering ‘telecommunication service’ to its subscribers. The activity, therefore, lies outside the ambit of ‘support service of business or commerce’ which is the ‘taxable service’ sought to be fastened on the appellant as ‘deemed provider’ under section 66A - AT
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