Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
The dominant issue was whether the marketing support and technical support services supplied to a foreign recipient under a master service agreement constituted "intermediary services" under section 2(13) of the IGST Act, thereby disentitling the supplier from treating the supply as export and claiming refund of accumulated input tax credit. On construing the agreement and contemporaneous records, it was held that the supplier was not arranging or facilitating supplies between two persons but providing services on its own account, satisfying the conditions for export of services. Consequently, the adjudication and appellate orders were set aside, the IGST demand was quashed, and refund was directed to be granted. - HC
The dominant issue was whether the marketing support and technical support services supplied to a foreign recipient under a master service agreement constituted "intermediary services" under section 2(13) of the IGST Act, thereby disentitling the supplier from treating the supply as export and claiming refund of accumulated input tax credit. On construing the agreement and contemporaneous records, it was held that the supplier was not arranging or facilitating supplies between two persons but providing services on its own account, satisfying the conditions for export of services. Consequently, the adjudication and appellate orders were set aside, the IGST demand was quashed, and refund was directed to be granted. - HC
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