Infrastructure-development deduction remains available to EPC contractors when substantive statutory conditions outweigh contractor labels in agreemen...
Explained Investment Sources: documented gifts and traceable salary savings supported deletion of additions for property and mutual-fund SIP investmen...
Internal comparable pricing supports arm's-length interest on compulsorily convertible debentures, preventing their recharacterisation as equity for t...
Nominee director protection shields independent financial-institution appointees from criminal liability where they lack involvement in deposit defaul...
HC ruled that the petitioner, providing design and engineering services to foreign recipients on a principal-to-principal basis, does not constitute an agency relationship. The court determined that the petitioner is an independent entity supplying services directly to its foreign counterparts, thereby qualifying as zero-rated supplies under Section 2(6) of IGST Act. Consequently, the petitioner is entitled to refund of unutilized Input Tax Credit relating to export services, including statutory interest under Section 56 of CGST Act. The petition was allowed, mandating the tax authorities to process the refund claim.
HC ruled that the petitioner, providing design and engineering services to foreign recipients on a principal-to-principal basis, does not constitute an agency relationship. The court determined that the petitioner is an independent entity supplying services directly to its foreign counterparts, thereby qualifying as zero-rated supplies under Section 2(6) of IGST Act. Consequently, the petitioner is entitled to refund of unutilized Input Tax Credit relating to export services, including statutory interest under Section 56 of CGST Act. The petition was allowed, mandating the tax authorities to process the refund claim.
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