Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
The Customs, Excise and Service Tax Appellate Tribunal (CESTAT) dismissed the Revenue's appeal. It held that the transaction between the parties constituted a job work arrangement, not a 'supply of tangible goods for use service'. The respondent installed machinery at the client's factory premises to carry out production activities using their own machines. No lease rent or consideration was charged for the 'supply of tangible goods for use'. The charges collected were for the production process on a job work basis, as evident from the invoices. Therefore, the demand of service tax under the 'supply of tangible goods for use service' was incorrect.
The Customs, Excise and Service Tax Appellate Tribunal (CESTAT) dismissed the Revenue's appeal. It held that the transaction between the parties constituted a job work arrangement, not a 'supply of tangible goods for use service'. The respondent installed machinery at the client's factory premises to carry out production activities using their own machines. No lease rent or consideration was charged for the 'supply of tangible goods for use'. The charges collected were for the production process on a job work basis, as evident from the invoices. Therefore, the demand of service tax under the 'supply of tangible goods for use service' was incorrect.
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