Charitable trust income application permits verified capital expenditure but rejects deferred pre-operative claims and requires reconsideration of con...
Reinsurance premium deductions require established regulatory breaches, while independently acquired software qualifies within the computer depreciati...
Rectification of mistake remains limited to self-evident record errors, preventing merits review through miscellaneous applications and preserving fin...
Tender creditworthiness conditions may extend to de facto Promoter Directors, with post-participation challenges generally barred absent arbitrariness...
Corporate representation in PMLA summons proceedings permitted through an authorised signatory, subject to directors' continuing cooperation and atten...
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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