Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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CENVAT Credit - input service availed by the appellant at the depot level - The case involved the admissibility of Cenvat Credit on service tax paid for clearing and forwarding services received by the appellant at the depot. The tribunal upheld the appellant's claim, stating that since the ownership of goods remained with them until sold from the depot or consignment agent premises, all input services availed up to that point were eligible for Cenvat Credit. The tribunal interpreted the definition of "place of removal" under the Central Excise Act, 1944, to include the depot of the consignment agent as the place of removal, making services provided up to that point admissible for credit.
CENVAT Credit - input service availed by the appellant at the depot level - The case involved the admissibility of Cenvat Credit on service tax paid for clearing and forwarding services received by the appellant at the depot. The tribunal upheld the appellant's claim, stating that since the ownership of goods remained with them until sold from the depot or consignment agent premises, all input services availed up to that point were eligible for Cenvat Credit. The tribunal interpreted the definition of "place of removal" under the Central Excise Act, 1944, to include the depot of the consignment agent as the place of removal, making services provided up to that point admissible for credit.
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