Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
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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