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...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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