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...
Levy of service tax - water charges paid - transfer of right to use the water by the Government to the appellant - Deemed sale - Since the agreement was for water supply, not services, the Tribunal found that service tax was not applicable to the water charges paid. - Considering the agreement's pre-2016 date, the Tribunal held that any services provided should be governed by pre-2016 provisions, exempting the appellant from tax liability. - Further, the Tribunal agreed with the appellant's argument that the water supply constituted the supply of goods, not services, aligning with the Finance Act's definition.
Levy of service tax - water charges paid - transfer of right to use the water by the Government to the appellant - Deemed sale - Since the agreement was for water supply, not services, the Tribunal found that service tax was not applicable to the water charges paid. - Considering the agreement's pre-2016 date, the Tribunal held that any services provided should be governed by pre-2016 provisions, exempting the appellant from tax liability. - Further, the Tribunal agreed with the appellant's argument that the water supply constituted the supply of goods, not services, aligning with the Finance Act's definition.
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