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...
Customs valuation and classification require comparable evidence and assessment of imported goods in their actual condition, invalidating related pena...
HC analyzed the classification of services under IGST Act, determining the petitioner's activities do not constitute intermediary services. The court found the service provider operates as an independent contractor, rendering services on its own account, not as an agent. Based on contractual analysis and precedent, the court held the services qualify as export of services. The refund claim was not time-barred, and the petitioner is entitled to unutilized ITC refund. The impugned orders demanding service tax were quashed, with the petition allowed partially, affirming the principal-to-principal nature of the contractual relationship and the extra-territorial supply of services.
HC analyzed the classification of services under IGST Act, determining the petitioner's activities do not constitute intermediary services. The court found the service provider operates as an independent contractor, rendering services on its own account, not as an agent. Based on contractual analysis and precedent, the court held the services qualify as export of services. The refund claim was not time-barred, and the petitioner is entitled to unutilized ITC refund. The impugned orders demanding service tax were quashed, with the petition allowed partially, affirming the principal-to-principal nature of the contractual relationship and the extra-territorial supply of services.
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