Charitable registration turns on predominant purpose and genuine activities, while incidental fees and related-party rent require supporting adverse m...
MAT book-profit adjustments exclude disallowances for exempt-income expenditure and demerger expenditure unless expressly listed under the statutory c...
Omitted specified domestic transaction provision invalidates related-party expenditure transfer-pricing references and assessments based on consequent...
Export of service - “intermediary service” or not - service rendered by the appellant to overseas universities/colleges - The Tribunal found that the appellant's services fit the criteria for "export of services." It noted that the appellant's activities were directed towards promoting foreign universities in India and assisting students with admissions, which directly benefited the universities outside India. Since the services were provided to recipients outside India, for which payment was received in convertible foreign exchange, these activities were deemed exports of services. - On examining the definition of "intermediary services," the Tribunal observed that the appellant did not merely arrange or facilitate the provision of services between two or more persons but provided substantial services on their own account to the foreign universities. Thus, it was determined that the appellant's services did not constitute "intermediary services."
Export of service - “intermediary service” or not - service rendered by the appellant to overseas universities/colleges - The Tribunal found that the appellant's services fit the criteria for "export of services." It noted that the appellant's activities were directed towards promoting foreign universities in India and assisting students with admissions, which directly benefited the universities outside India. Since the services were provided to recipients outside India, for which payment was received in convertible foreign exchange, these activities were deemed exports of services. - On examining the definition of "intermediary services," the Tribunal observed that the appellant did not merely arrange or facilitate the provision of services between two or more persons but provided substantial services on their own account to the foreign universities. Thus, it was determined that the appellant's services did not constitute "intermediary services."
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