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...
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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