Charitable trust registration requires a specified-violation notice; settled cash deposits and related-party payments did not justify cancellation or ...
External development charges trigger TDS under section 194C, while disputed administrative payments require factual verification and fresh adjudicatio...
Section 270AA penalty immunity requires identified statutory defaults and a hearing before rejection; reassessment disclosure may constitute under-rep...
Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
CESTAT determined no service tax liability existed under Reverse Charge Mechanism for payment processing services from AFL and foreign banks. The tribunal found no direct service provider-recipient relationship between appellant and foreign entities. Charges deducted by foreign banks during remittance process were part of trade arrangements, not constituting taxable services. Following precedents in AKR Textile and SKM Egg Products cases, the tribunal held that remittance services by foreign banks to Indian banks for exporters are not subject to service tax. For post-July 2012 period, services performed by Hong Kong intermediary were outside taxable territory. The appeal was allowed, setting aside the original tax demand.
CESTAT determined no service tax liability existed under Reverse Charge Mechanism for payment processing services from AFL and foreign banks. The tribunal found no direct service provider-recipient relationship between appellant and foreign entities. Charges deducted by foreign banks during remittance process were part of trade arrangements, not constituting taxable services. Following precedents in AKR Textile and SKM Egg Products cases, the tribunal held that remittance services by foreign banks to Indian banks for exporters are not subject to service tax. For post-July 2012 period, services performed by Hong Kong intermediary were outside taxable territory. The appeal was allowed, setting aside the original tax demand.
Note: It is a system-generated summary and is for quick reference only.