Aggregation under TNMM prevents selective testing of intra-group services without comparable uncontrolled transactions, while appellate additional cla...
Protective assessment cannot duplicate identical receipts under competing characterisations; remote services did not establish a taxable permanent est...
Current account treatment of overseas tournament services removed most FEMA findings, but excess EEFC remittance and delayed repatriation remained bre...
Modification of bail conditions remains available through inherent jurisdiction where onerous deposits undermine justice and cannot recover disputed d...
Merchant banker regulation consolidates registration, governance, capital, reporting, outsourcing and investor-protection requirements under an update...
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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