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...
Demand of service tax - GTA - it is settled that the goods for the purpose of Goods Transport Agency service should be qualified as "goods‟ in terms of definition given under Section 65(50) of Finance Act, 1994. Therefore, in the present case the goods being effluent which is neither sold nor saleable, does not qualify in terms “goods”. Therefore, transportation of the same does not fall under the four corners of Goods Transport Agency service, hence the same is not liable to service tax - AT
Demand of service tax - GTA - it is settled that the goods for the purpose of Goods Transport Agency service should be qualified as "goods‟ in terms of definition given under Section 65(50) of Finance Act, 1994. Therefore, in the present case the goods being effluent which is neither sold nor saleable, does not qualify in terms “goods”. Therefore, transportation of the same does not fall under the four corners of Goods Transport Agency service, hence the same is not liable to service tax - AT
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