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...
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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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