Composite inpatient healthcare supply may retain exemption despite MRP medicine billing, while separate taxable sale characterisation remains disputed...
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...
The CESTAT held that the extended period of limitation invoked for levying service tax was unsustainable as there was no wilful suppression of facts by the appellant. The demands of Rs.1,01,6,502/- under 'sponsorship' services, Rs.13,30,558/- on inter-company expenses, and Rs.20,371/- as interest were set aside. For renting services, the demand of Rs.2,45,58,483/- was set aside, and the appellant was directed to produce evidence for the remaining Rs.34,29,130/-. The demands of Rs.73,00,732/- for import of services and Rs.2,80,40,921/- for software licenses were remanded for de-novo adjudication to determine the appellant's role and liabilities. The penalties were also set aside. The appeal was disposed of accordingly.
The CESTAT held that the extended period of limitation invoked for levying service tax was unsustainable as there was no wilful suppression of facts by the appellant. The demands of Rs.1,01,6,502/- under 'sponsorship' services, Rs.13,30,558/- on inter-company expenses, and Rs.20,371/- as interest were set aside. For renting services, the demand of Rs.2,45,58,483/- was set aside, and the appellant was directed to produce evidence for the remaining Rs.34,29,130/-. The demands of Rs.73,00,732/- for import of services and Rs.2,80,40,921/- for software licenses were remanded for de-novo adjudication to determine the appellant's role and liabilities. The penalties were also set aside. The appeal was disposed of accordingly.
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