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...
Classification of interest charged by a manufacturer on delayed payments from customers for the sale of excisable goods. The key points are: The interest was classified as a declared service u/s 66E(e) of the Finance Act, making it liable for service tax. However, relying on the Supreme Court's judgment in South Eastern Coalfields Ltd., it was held that penal interest on delayed payments cannot be subject to service tax u/s 66E(e). Consequently, the order classifying the interest as a taxable service was set aside, and the appeal was allowed with consequential relief, following the ratio decidendi of the Supreme Court case.
Classification of interest charged by a manufacturer on delayed payments from customers for the sale of excisable goods. The key points are: The interest was classified as a declared service u/s 66E(e) of the Finance Act, making it liable for service tax. However, relying on the Supreme Court's judgment in South Eastern Coalfields Ltd., it was held that penal interest on delayed payments cannot be subject to service tax u/s 66E(e). Consequently, the order classifying the interest as a taxable service was set aside, and the appeal was allowed with consequential relief, following the ratio decidendi of the Supreme Court case.
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