Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Demand of differential service tax - Valuation - non-inclusion on reimbursable expenses - pure agent services - The Appellate Tribunal analyzed the agreements and legal provisions, including previous tribunal decisions and the Service Tax (Determination of Value) Rules, 2006. It concluded that the appellant indeed acted as a pure agent and that reimbursable expenses should not be considered part of taxable services. Consequently, the Tribunal set aside the impugned order, allowing the appeal with consequential relief.
Demand of differential service tax - Valuation - non-inclusion on reimbursable expenses - pure agent services - The Appellate Tribunal analyzed the agreements and legal provisions, including previous tribunal decisions and the Service Tax (Determination of Value) Rules, 2006. It concluded that the appellant indeed acted as a pure agent and that reimbursable expenses should not be considered part of taxable services. Consequently, the Tribunal set aside the impugned order, allowing the appeal with consequential relief.
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