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Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Intermediary services are distinguished from principal-to-principal supplies: where a supplier contracts directly with and is paid by a foreign university the supplier is not an intermediary but provides marketing services on a principal-to-principal basis, making those services export of services and placing the supply at the recipient's location outside India. Consultancy services supplied to students for a fee qualify as taxable 'supply' under the CGST Act and attract GST. Services provided free to students, lacking consideration and not covered by Schedule I, are not 'supply'. Exported services meeting IGST conditions are eligible for zero-rated treatment and refund subject to verification.
Intermediary services are distinguished from principal-to-principal supplies: where a supplier contracts directly with and is paid by a foreign university the supplier is not an intermediary but provides marketing services on a principal-to-principal basis, making those services export of services and placing the supply at the recipient's location outside India. Consultancy services supplied to students for a fee qualify as taxable 'supply' under the CGST Act and attract GST. Services provided free to students, lacking consideration and not covered by Schedule I, are not 'supply'. Exported services meeting IGST conditions are eligible for zero-rated treatment and refund subject to verification.
Note: It is a system-generated summary and is for quick reference only.