Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Refund claim - export of service - zero rated supply - receipt in convertible foreign exchange - Amount received through Paypal in Indian currency - The High Court observed that payments received through PayPal, acting as an intermediary, and credited in Indian Rupees after conversion, complied with the FEMA regulations and RBI guidelines. - The court determined that the failure to directly receive payments in foreign currency or produce export invoices does not automatically disqualify the petitioner from refund eligibility, as the essence of the transactions met the criteria for "export of service". - Consequently, the petitioner is entitled for export of tax paid on export and the unutilized input tax credit used in export of service. - Refund allowed.
Refund claim - export of service - zero rated supply - receipt in convertible foreign exchange - Amount received through Paypal in Indian currency - The High Court observed that payments received through PayPal, acting as an intermediary, and credited in Indian Rupees after conversion, complied with the FEMA regulations and RBI guidelines. - The court determined that the failure to directly receive payments in foreign currency or produce export invoices does not automatically disqualify the petitioner from refund eligibility, as the essence of the transactions met the criteria for "export of service". - Consequently, the petitioner is entitled for export of tax paid on export and the unutilized input tax credit used in export of service. - Refund allowed.
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