Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
The Customs, Excise and Service Tax Appellate Tribunal (CESTAT) held that the appellants did not render intermediary services for their foreign principal. The services provided by the appellants were classified as export of services, making them eligible for refund of unutilized CENVAT credit. However, the matter was remanded to the original authority to calculate the eligible refund amount based on actual foreign remittances received during the respective quarters, as the appellants failed to submit certain Foreign Inward Remittance Certificates (FIRCs). The appeals were disposed of accordingly.
The Customs, Excise and Service Tax Appellate Tribunal (CESTAT) held that the appellants did not render intermediary services for their foreign principal. The services provided by the appellants were classified as export of services, making them eligible for refund of unutilized CENVAT credit. However, the matter was remanded to the original authority to calculate the eligible refund amount based on actual foreign remittances received during the respective quarters, as the appellants failed to submit certain Foreign Inward Remittance Certificates (FIRCs). The appeals were disposed of accordingly.
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TaxTMI 
TaxTMI 
of 4879 
