Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
FEMA borrowing restrictions bind charitable trusts, and civil penalties apply without proving intent for delayed repayment of non-resident rupee loans...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4881 
