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 - supplementary invoice - cost escalation clause - to be taxed at 12% or at 10% - the taxable events in the present Appeal had admittedly occurred prior to 01.04.2012. At that point of time the rate of Service Tax applicable in respect of services in question was 10% and not 12% which came into effect only on or after 01.04.2012 - The issuance of supplementary invoices in the month of July 2012 would not make any difference because it is not receipt of payment which is taxable event, but the rendition of service. - AT
Levy of service tax - supplementary invoice - cost escalation clause - to be taxed at 12% or at 10% - the taxable events in the present Appeal had admittedly occurred prior to 01.04.2012. At that point of time the rate of Service Tax applicable in respect of services in question was 10% and not 12% which came into effect only on or after 01.04.2012 - The issuance of supplementary invoices in the month of July 2012 would not make any difference because it is not receipt of payment which is taxable event, but the rendition of service. - AT
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