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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
