Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
The HC dismissed the writ petition. The court held that the Respondent, an educational consultant, is a supplier of services - not an "intermediary" - because it provides consultancy directly to students and invoices the foreign educational institutions (FEIs) for services rendered; receipt of payment in foreign exchange does not convert the relationship into an intermediary agency. Consequently the services qualify as export of services under the IGST framework and the intermediary exception does not apply; the place of supply rules are governed by Section 13(2) where applicable. Having so determined, the petition seeking relief was not maintainable and is dismissed.
The HC dismissed the writ petition. The court held that the Respondent, an educational consultant, is a supplier of services - not an "intermediary" - because it provides consultancy directly to students and invoices the foreign educational institutions (FEIs) for services rendered; receipt of payment in foreign exchange does not convert the relationship into an intermediary agency. Consequently the services qualify as export of services under the IGST framework and the intermediary exception does not apply; the place of supply rules are governed by Section 13(2) where applicable. Having so determined, the petition seeking relief was not maintainable and is dismissed.
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