Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
The dispute concerned whether services supplied to state-established or wholly state owned bodies qualify as services to a "governmental authority" for exemption under entries 12 and 12A of Notification No.25/2012 ST. The tribunal applied a disjunctive reading of "or" in the definition and, noting that the definition had been amended (and considered by the SC), held that bodies established by the State Legislature or wholly owned by the State qualify as governmental authorities; consequence: the exemption applies to services rendered to those bodies for the period in issue. Revenue's appeal against allowing the exemption was dismissed.
The dispute concerned whether services supplied to state-established or wholly state owned bodies qualify as services to a "governmental authority" for exemption under entries 12 and 12A of Notification No.25/2012 ST. The tribunal applied a disjunctive reading of "or" in the definition and, noting that the definition had been amended (and considered by the SC), held that bodies established by the State Legislature or wholly owned by the State qualify as governmental authorities; consequence: the exemption applies to services rendered to those bodies for the period in issue. Revenue's appeal against allowing the exemption was dismissed.
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