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...
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The appellants are not intermediaries but provide payment processing services to Airbnb, Ireland on a principal-to-principal basis. The conditions for being an intermediary under the Genpact case are not satisfied as there is no principal-agent relationship, and the appellants do not facilitate the main service provided by Airbnb. The appellants merely process payments to ensure property owners receive consideration for renting to Airbnb, without any involvement with Airbnb's customers. The appellants provide a single service of payment processing to Airbnb and have no tripartite agreement or commission-based arrangement. Their services qualify as export of services u/r 6A of the Service Tax Rules, making them eligible for refunds claimed and not liable for service tax. Consequently, the impugned orders are set aside, and the appeal is allowed.
The appellants are not intermediaries but provide payment processing services to Airbnb, Ireland on a principal-to-principal basis. The conditions for being an intermediary under the Genpact case are not satisfied as there is no principal-agent relationship, and the appellants do not facilitate the main service provided by Airbnb. The appellants merely process payments to ensure property owners receive consideration for renting to Airbnb, without any involvement with Airbnb's customers. The appellants provide a single service of payment processing to Airbnb and have no tripartite agreement or commission-based arrangement. Their services qualify as export of services u/r 6A of the Service Tax Rules, making them eligible for refunds claimed and not liable for service tax. Consequently, the impugned orders are set aside, and the appeal is allowed.
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