Dispute Resolution Panel objections must reach both prescribed forums; otherwise assessment may proceed and statutory appeal remains the proper remedy...
Political contribution deductions require recipient party compliance with contribution-reporting conditions; banking-channel donations alone do not qu...
Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
The respondent's services rendered to their parent company in the USA are classified as an 'intermediary service' or 'export service'. The basic requirement for an intermediary is the presence of at least three parties, where the intermediary arranges or facilitates the supply of goods or services between two or more other persons but does not provide the main supply. The case is similar to an illustration where a BPO firm provides customer care services to a manufacturer by interacting with the manufacturer's customers, charging the manufacturer for this service. The BPO firm is involved in supplying the main service of customer care to the manufacturer and is not an intermediary. Therefore, the respondent's services are not considered an intermediary service, and the Revenue's appeal lacks merit.
The respondent's services rendered to their parent company in the USA are classified as an 'intermediary service' or 'export service'. The basic requirement for an intermediary is the presence of at least three parties, where the intermediary arranges or facilitates the supply of goods or services between two or more other persons but does not provide the main supply. The case is similar to an illustration where a BPO firm provides customer care services to a manufacturer by interacting with the manufacturer's customers, charging the manufacturer for this service. The BPO firm is involved in supplying the main service of customer care to the manufacturer and is not an intermediary. Therefore, the respondent's services are not considered an intermediary service, and the Revenue's appeal lacks merit.
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