Co-operative society's mandatory reserve and share capital fixed deposits with banks-interest treated as business income under 80P(2)(a)(iii) deductio...
Income tax reassessment reopening after four years on investigation tip, without s.147 proviso disclosure failure, struck down as borrowed satisfactio...
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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