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...
The HC held that the petitioner was providing export of services to its US parent company, not intermediary services. The petitioner assisted the parent in business consultancy by setting up meetings with experts/clients and providing advisory services. The payment terms showed the petitioner earned 8% markup, operating independently. Following Ernst & Young, since the recipient was outside India, the services qualified as export u/s 2(6) IGST Act. The HC set aside the orders treating it as intermediary service and directed processing of the refund claim as export of services filed within limitation.
The HC held that the petitioner was providing export of services to its US parent company, not intermediary services. The petitioner assisted the parent in business consultancy by setting up meetings with experts/clients and providing advisory services. The payment terms showed the petitioner earned 8% markup, operating independently. Following Ernst & Young, since the recipient was outside India, the services qualified as export u/s 2(6) IGST Act. The HC set aside the orders treating it as intermediary service and directed processing of the refund claim as export of services filed within limitation.
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