Intermediary service classification fails where overseas admission facilitation is supplied independently, preserving export treatment and small-provi...
Satellite transponder bandwidth is telecommunication, not Business Support Service; foreign non-telegraph providers triggered no service tax liability...
Commitment proceedings gain extended timelines, structured defect refiling, and automatic resumption of inquiry after the adjusted completion period e...
Centralised assessment transfer becomes unwarranted once the searched person's assessment is complete, requiring restoration to the appropriate charge...
Transfer Pricing Adjustments on Corporate Guarantee Charges, Interest on Optionally Convertible Loans (OCL), and Reimbursement of Expenses. - The Tribunal found that these issues were adjudicated in favor of the assessee in previous years, relying on ITAT and High Court decisions. The adjustments made by the AO were not upheld, and the tribunal directed the deletion of these adjustments, affirming the assessee's approach to charging 1% corporate guarantee fees and handling of OCL and reimbursement of expenses as per the precedents.
Transfer Pricing Adjustments on Corporate Guarantee Charges, Interest on Optionally Convertible Loans (OCL), and Reimbursement of Expenses. - The Tribunal found that these issues were adjudicated in favor of the assessee in previous years, relying on ITAT and High Court decisions. The adjustments made by the AO were not upheld, and the tribunal directed the deletion of these adjustments, affirming the assessee's approach to charging 1% corporate guarantee fees and handling of OCL and reimbursement of expenses as per the precedents.
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