Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Demand of service tax on amounts collected as penalties under various contracts - The petitioner argued that these amounts did not involve any value addition or service element, thus not attracting service tax liability. - The petitioner relied on a circular dated 3.8.2022 and a judgment of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT), which influenced the decision not to challenge the orders. The court needed to consider the implications of these subsequent events on the original show cause notice. - Matter restored back.
Demand of service tax on amounts collected as penalties under various contracts - The petitioner argued that these amounts did not involve any value addition or service element, thus not attracting service tax liability. - The petitioner relied on a circular dated 3.8.2022 and a judgment of the Customs, Excise and Service Tax Appellate Tribunal (CESTAT), which influenced the decision not to challenge the orders. The court needed to consider the implications of these subsequent events on the original show cause notice. - Matter restored back.
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