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 adjudicated a service tax dispute involving OIDAR services contracted by an overseas head office with CRS/GDS companies. The tribunal held that services provided between entities in Singapore and Hong Kong fall outside service tax levy under Section 66. The Indian branch office was not deemed liable for service tax on reverse charge basis, as the services were conducted exclusively between non-Indian entities. The tribunal distinguished between head office and branch office legal identities, concluding that the branch office cannot be compelled to pay service tax for transactions not directly involving Indian territorial jurisdiction. The impugned order was set aside, and the appeal was allowed.
CESTAT adjudicated a service tax dispute involving OIDAR services contracted by an overseas head office with CRS/GDS companies. The tribunal held that services provided between entities in Singapore and Hong Kong fall outside service tax levy under Section 66. The Indian branch office was not deemed liable for service tax on reverse charge basis, as the services were conducted exclusively between non-Indian entities. The tribunal distinguished between head office and branch office legal identities, concluding that the branch office cannot be compelled to pay service tax for transactions not directly involving Indian territorial jurisdiction. The impugned order was set aside, and the appeal was allowed.
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