Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Classification of service - Business Support services or not - The Appellate Tribunal, referring to precedent cases, concluded that GTPL's activity of arranging transportation did not qualify as business support service. They emphasized that GTPL solely organized transportation without providing loading/unloading or other logistics services. The tribunal found no evidence of a contract for the provision of business support service between GTPL and their buyers. Therefore, they dismissed the revenue's claim regarding the nature of the service provided by GTPL.
Classification of service - Business Support services or not - The Appellate Tribunal, referring to precedent cases, concluded that GTPL's activity of arranging transportation did not qualify as business support service. They emphasized that GTPL solely organized transportation without providing loading/unloading or other logistics services. The tribunal found no evidence of a contract for the provision of business support service between GTPL and their buyers. Therefore, they dismissed the revenue's claim regarding the nature of the service provided by GTPL.
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