Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
Page of 4828
Press 'Enter' after typing page number.
161 to 180 of 96556 Results
❮
❯
❯❯
0 / 200
Expand Note
Add to Folder
No Folders have been created
+
Are you sure you want to delete "My most important" ?
Reverse charge mechanism on commission paid to foreign commission agents does not attract service tax liability. Documentary evidence shows no direct payment made to commission agents by appellant, rather deduction from total invoice value raised on foreign buyer constitutes trade discount. Absence of contractual relationship between appellant and foreign service provider, coupled with lack of direct transaction, precludes service tax demand on commission shown in buyer's invoice. Tribunal relied on precedents in Laxmi Exports and Aquamarine Exports cases, where commission deducted was held as trade discount not subjected to service tax. Issue settled in favor of assessee, demand of service tax on commission deducted in sale invoice to foreign buyer not chargeable. Impugned order set aside, appeal allowed.
Reverse charge mechanism on commission paid to foreign commission agents does not attract service tax liability. Documentary evidence shows no direct payment made to commission agents by appellant, rather deduction from total invoice value raised on foreign buyer constitutes trade discount. Absence of contractual relationship between appellant and foreign service provider, coupled with lack of direct transaction, precludes service tax demand on commission shown in buyer's invoice. Tribunal relied on precedents in Laxmi Exports and Aquamarine Exports cases, where commission deducted was held as trade discount not subjected to service tax. Issue settled in favor of assessee, demand of service tax on commission deducted in sale invoice to foreign buyer not chargeable. Impugned order set aside, appeal allowed.
Note: It is a system-generated summary and is for quick reference only.