Development agreements require legal possession or effective enjoyment for capital gains transfer; permissive possession and deferred consideration de...
Prolonged sterilisation of development rights supports capital-gains treatment, while business-income disallowances cannot govern capital-gains comput...
Additional evidence in transfer pricing dispute leads to fresh examination, while tax deductions, TDS credit, fee and refund interest require verifica...
Category II AIF pass-through taxation preserves non-business income character; investment receipts cannot be reclassified without applying recognised ...
Services rendered to foreign affiliates were examined to determine whether they constituted export of services and whether GST could be levied on "data management services." Applying para 3.2 of Circular No. 209/1/2018-ST, the place of provision for software-related services including testing, debugging, modification, customisation, upgradation, enhancement and implementation is the recipient's location. On construing the master service agreement and the nature of activities, the services were held to fall within "data management services" covered by the circular, making the place of supply outside India; consequently, the GST demand (and allied interest/penalty) on such services was set aside and the impugned order was quashed. - HC
Services rendered to foreign affiliates were examined to determine whether they constituted export of services and whether GST could be levied on "data management services." Applying para 3.2 of Circular No. 209/1/2018-ST, the place of provision for software-related services including testing, debugging, modification, customisation, upgradation, enhancement and implementation is the recipient's location. On construing the master service agreement and the nature of activities, the services were held to fall within "data management services" covered by the circular, making the place of supply outside India; consequently, the GST demand (and allied interest/penalty) on such services was set aside and the impugned order was quashed. - HC
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