Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4879 
