Agency in CNG distribution makes outlet operators commission agents, rendering taxable Business Auxiliary Service rather than purchasing goods for res...
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Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Whether services treated as local supply could be reclassified as export by denying refund on the ground that the claimant was an "intermediary" under GST law was the dominant issue. On examining the record and applying settled principles on intermediary services, it was held that the claimant was not an intermediary and the services qualified as export, entitling it to refund of accumulated/unutilized ITC. Consequently, the refund rejection orders were quashed and the authorities were directed to sanction the refund with applicable interest within three months; the matter was remanded for consequential compliance. - HC
Whether services treated as local supply could be reclassified as export by denying refund on the ground that the claimant was an "intermediary" under GST law was the dominant issue. On examining the record and applying settled principles on intermediary services, it was held that the claimant was not an intermediary and the services qualified as export, entitling it to refund of accumulated/unutilized ITC. Consequently, the refund rejection orders were quashed and the authorities were directed to sanction the refund with applicable interest within three months; the matter was remanded for consequential compliance. - HC
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