Business reorganisation requires recognition of successor's modified return; draft orders against dissolved transferor quashed and fresh review direct...
Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
A declared service under Section 66E(e) requires a contractual consideration; pre agreed compensation for idle or underutilised production capacity treated as part of the agreed remuneration qualifies as such consideration and therefore falls within the declared service entry. Under the Place of Provision of Services Rules, the general destination principle applies where services are not directly tied to immovable property, so the place of provision is the location of the service recipient. Because the arrangement concerned manufacture and remuneration for capacity held for a foreign recipient, the service was treated as provided outside India and qualified as export of services, negating the departmental demand.
A declared service under Section 66E(e) requires a contractual consideration; pre agreed compensation for idle or underutilised production capacity treated as part of the agreed remuneration qualifies as such consideration and therefore falls within the declared service entry. Under the Place of Provision of Services Rules, the general destination principle applies where services are not directly tied to immovable property, so the place of provision is the location of the service recipient. Because the arrangement concerned manufacture and remuneration for capacity held for a foreign recipient, the service was treated as provided outside India and qualified as export of services, negating the departmental demand.
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