Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
Rejection of Refund claim - Whether the service provided by the appellant to GSPHCL is service provided to a governmental authority? - The GSPHCL is a 100% owned by Government of Gujarat therefore, it clearly falls under the category of service provided to government authority - The corporation/board constituted under the act of State Government should be considered as a governmental authority and accordingly, exemption provided to the government or governmental authority is applicable in respect of service provided by a service provider to such board/corporation. - AT
Rejection of Refund claim - Whether the service provided by the appellant to GSPHCL is service provided to a governmental authority? - The GSPHCL is a 100% owned by Government of Gujarat therefore, it clearly falls under the category of service provided to government authority - The corporation/board constituted under the act of State Government should be considered as a governmental authority and accordingly, exemption provided to the government or governmental authority is applicable in respect of service provided by a service provider to such board/corporation. - AT
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