Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Reverse charge mechanism (RCM) - Liability of recipient of service to pay service tax - deemed services - The Appellants have received goods from entities located outside India whereas the services in respect of the said goods have been provided to the Appellants by the parent company’s branch in India -The CESTAT ruled that appellants engaged in exporting cut and polished diamonds were not liable to pay Service Tax under Reverse Charge Mechanism for services received from a foreign country, as the services were provided through their Indian subsidiary, establishing a permanent establishment in India under Section 66A of the Finance Act, 1994.
Reverse charge mechanism (RCM) - Liability of recipient of service to pay service tax - deemed services - The Appellants have received goods from entities located outside India whereas the services in respect of the said goods have been provided to the Appellants by the parent company’s branch in India -The CESTAT ruled that appellants engaged in exporting cut and polished diamonds were not liable to pay Service Tax under Reverse Charge Mechanism for services received from a foreign country, as the services were provided through their Indian subsidiary, establishing a permanent establishment in India under Section 66A of the Finance Act, 1994.
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