Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
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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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