Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
Nature of activity - sale or service - The appellant procured COA/stickers/labels under a Microsoft OEM Customer License Agreement, affixing them to Thin Clients installed with Microsoft software, questioning whether this constituted a sale of goods or a service under ITSS. - The tribunal held that merely affixing stickers/labels, providing authenticity to software loaded onto Thin Clients, does not constitute a 'service' received under ITSS. It distinguished the transaction from the distribution/sale of software, focusing on the sale of embedded systems without transferring copyright. Thus, the transaction was deemed a 'sale' of goods, not a service taxable under ITSS.
Nature of activity - sale or service - The appellant procured COA/stickers/labels under a Microsoft OEM Customer License Agreement, affixing them to Thin Clients installed with Microsoft software, questioning whether this constituted a sale of goods or a service under ITSS. - The tribunal held that merely affixing stickers/labels, providing authenticity to software loaded onto Thin Clients, does not constitute a 'service' received under ITSS. It distinguished the transaction from the distribution/sale of software, focusing on the sale of embedded systems without transferring copyright. Thus, the transaction was deemed a 'sale' of goods, not a service taxable under ITSS.
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