Composite supply of drilling services and site specific chemicals characterised as composite supply; prior advance rulings set aside, tax rate left op...
Cross country pipeline classification and ITC entitlement: pipelines outside factory treated as immovable, ITC disallowed under Section 17 restriction...
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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