Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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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