Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
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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