Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Location of supplier and 'place of business' depend on where the supplier ordinarily runs the business; therefore the place from which supplies are made determines the location of services - outcome: services are located at the Head Office (HO). Whether FSEs constitute an agent or create a place of business was addressed by noting FSEs are employees who do not contract with customers independently and can be withdrawn by the HO - outcome: FSE presence in Odisha is not a separate place of business or fixed establishment. Registration liability follows the supplier location; outcome: no separate GST registration required in Odisha.
Location of supplier and 'place of business' depend on where the supplier ordinarily runs the business; therefore the place from which supplies are made determines the location of services - outcome: services are located at the Head Office (HO). Whether FSEs constitute an agent or create a place of business was addressed by noting FSEs are employees who do not contract with customers independently and can be withdrawn by the HO - outcome: FSE presence in Odisha is not a separate place of business or fixed establishment. Registration liability follows the supplier location; outcome: no separate GST registration required in Odisha.
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