Windmill commissioning evidence supported higher depreciation where grid connection and electricity generation proved operational use before the relev...
Pharmaceutical promotion and transfer-pricing comparability principles limited disallowances, while uncorroborated search allegations and unsupported ...
Business expenditure substantiation supports scrap credits, statutory payments and expense claims, while depreciation requires proof of actual busines...
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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