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...
Levy of service tax - Intellectual Property Services - The Tribunal observed that the technology transfer did not qualify as intellectual property rights under Section 65(55a) of the Act, as it was confidential and not registered under Indian law. Therefore, it did not fall under the definition of intellectual property services as per Section 65(55b). Referring to past cases and Circular No. 80/2010/2004-S.T., the Tribunal concluded that the appellant was not liable to pay service tax on the license fees and incidental expenses to the Russian company.
Levy of service tax - Intellectual Property Services - The Tribunal observed that the technology transfer did not qualify as intellectual property rights under Section 65(55a) of the Act, as it was confidential and not registered under Indian law. Therefore, it did not fall under the definition of intellectual property services as per Section 65(55b). Referring to past cases and Circular No. 80/2010/2004-S.T., the Tribunal concluded that the appellant was not liable to pay service tax on the license fees and incidental expenses to the Russian company.
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