Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4828 
Join Channel 
