Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
Pre-enactment land-sale agreements escape stamp-duty value substitution where substantial banking-channel consideration was received before Section 43...
Appellant liable to pay service tax on 'Cleaning activity' services provided to Indian Railways and public sector undertakings as per Madras HC's decision in Premier Garment Process case. Service tax payable on gross amount including employee wages, unless appellant is pure agent as per Supreme Court's Intercontinental Consultants judgment. Secondary packaging activity not manufacturing, hence not under service tax. Transportation of documents and goods not 'Manpower Recruitment or Supply Agency' service but 'Transportation of Goods' under reverse charge. Appellant eligible for Notification No. 30/2012-ST benefit and cum-tax benefit u/s 67(2). Matter remanded to adjudication authority to quantify service tax liability on cleaning and manpower supply services for normal period, considering pure agent contracts, and allowing notification benefit. Appeal partly allowed.
Appellant liable to pay service tax on 'Cleaning activity' services provided to Indian Railways and public sector undertakings as per Madras HC's decision in Premier Garment Process case. Service tax payable on gross amount including employee wages, unless appellant is pure agent as per Supreme Court's Intercontinental Consultants judgment. Secondary packaging activity not manufacturing, hence not under service tax. Transportation of documents and goods not 'Manpower Recruitment or Supply Agency' service but 'Transportation of Goods' under reverse charge. Appellant eligible for Notification No. 30/2012-ST benefit and cum-tax benefit u/s 67(2). Matter remanded to adjudication authority to quantify service tax liability on cleaning and manpower supply services for normal period, considering pure agent contracts, and allowing notification benefit. Appeal partly allowed.
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