Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Taxable service or not - Intermediary services - Valuation - Inclusion of the cost / value of free supply - The Tribunal agreed with the appellant, finding that the services received from the European company were indeed intermediary services as per the criteria laid out in POPS and the CBIC’s Education Guide. Consequently, the place of provision of such services was outside India (Dubai), making them not liable for service tax. - Aligning with the judgment in Bhayana Builders Pvt. Ltd. and subsequent confirmation by the Supreme Court, the Tribunal held that the value of materials supplied free of cost to service providers in a works contract could not be included in the taxable value for the purpose of service tax.
Taxable service or not - Intermediary services - Valuation - Inclusion of the cost / value of free supply - The Tribunal agreed with the appellant, finding that the services received from the European company were indeed intermediary services as per the criteria laid out in POPS and the CBIC’s Education Guide. Consequently, the place of provision of such services was outside India (Dubai), making them not liable for service tax. - Aligning with the judgment in Bhayana Builders Pvt. Ltd. and subsequent confirmation by the Supreme Court, the Tribunal held that the value of materials supplied free of cost to service providers in a works contract could not be included in the taxable value for the purpose of service tax.
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