Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Denial of exemption - Demand beyond the scope of the Show Cause Notice (SCN) - Procurement of GTA service for export - When the return itself requires the details, there is no requirement for the show cause notice to specify in the said details, as has been submitted by the learned counsel for the appellant. - the appellant has complied with the notification condition as enumerated in column 4 of the aforesaid table. In view of the same, the demand of duty and interest is set aside. - AT
Denial of exemption - Demand beyond the scope of the Show Cause Notice (SCN) - Procurement of GTA service for export - When the return itself requires the details, there is no requirement for the show cause notice to specify in the said details, as has been submitted by the learned counsel for the appellant. - the appellant has complied with the notification condition as enumerated in column 4 of the aforesaid table. In view of the same, the demand of duty and interest is set aside. - AT
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