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 ...
Classification of services - management and business consultant service - The tribunal held that the activity of disbursal of wages to the unskilled rural labours as a measure of employment generation under Mahatma Gandhi National Rural Employment Guarantee Act (MGNREGA), does not cover under “Management and Business Consultant” Services. Therefore, for the period prior to 01.07.2012, the appellants are not liable to pay service tax. - Merely because, there was an agreement and in terms of the agreement, the service tax was inclusive which is to be borne to the appellants, no demand of service tax can be sustained.
Classification of services - management and business consultant service - The tribunal held that the activity of disbursal of wages to the unskilled rural labours as a measure of employment generation under Mahatma Gandhi National Rural Employment Guarantee Act (MGNREGA), does not cover under “Management and Business Consultant” Services. Therefore, for the period prior to 01.07.2012, the appellants are not liable to pay service tax. - Merely because, there was an agreement and in terms of the agreement, the service tax was inclusive which is to be borne to the appellants, no demand of service tax can be sustained.
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