Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
CESTAT held that services provided by appellant to overseas educational institutions constituted export of services, not intermediary services. The appellant rendered services directly to foreign universities/colleges and received commission upon successful student admissions. These services satisfied all conditions under Rule 6A for classification as export services, including direct provision to foreign recipients with payment in foreign exchange. Following precedent established in Sunrise Immigration Consultants Private Limited, the Tribunal determined that referral services for foreign universities qualify as export services when the provider acts on its own account rather than as an intermediary. Appeal allowed.
CESTAT held that services provided by appellant to overseas educational institutions constituted export of services, not intermediary services. The appellant rendered services directly to foreign universities/colleges and received commission upon successful student admissions. These services satisfied all conditions under Rule 6A for classification as export services, including direct provision to foreign recipients with payment in foreign exchange. Following precedent established in Sunrise Immigration Consultants Private Limited, the Tribunal determined that referral services for foreign universities qualify as export services when the provider acts on its own account rather than as an intermediary. Appeal allowed.
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