Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
The CESTAT allowed the appeal filed by the appellant against the demands raised for service tax on franchise service, maintenance or repair service, commercial training or coaching service, management or business consultant service, reimbursable expenses, and manpower recruitment and supply service. The Tribunal held that the appellant cannot be treated as a franchisee or representative of Aircom International Company, U.K., based on the terms of the agreement between them. Regarding the other services, the Tribunal found that the show cause notice lacked proper identification of service recipients, consideration paid, and reasoned grounds for demand, rendering the allegations unsubstantiated. Consequently, the demands along with interest and penalties were set aside.
The CESTAT allowed the appeal filed by the appellant against the demands raised for service tax on franchise service, maintenance or repair service, commercial training or coaching service, management or business consultant service, reimbursable expenses, and manpower recruitment and supply service. The Tribunal held that the appellant cannot be treated as a franchisee or representative of Aircom International Company, U.K., based on the terms of the agreement between them. Regarding the other services, the Tribunal found that the show cause notice lacked proper identification of service recipients, consideration paid, and reasoned grounds for demand, rendering the allegations unsubstantiated. Consequently, the demands along with interest and penalties were set aside.
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