Retention of seized property survives where recorded reasons support proceeds of crime, while stayed investigation periods are excluded from limitatio...
Specified income of Baddi Barotiwala Nalagarh Development Authority receives conditional tax exemption, retrospectively covering its designated assess...
Specified development authority income receives retrospective tax exemption, subject to non-commercial activity, unchanged income sources, and return-...
Unified Brand India framework introduces voluntary Trust Mark certification and funding support for export branding, packaging and global promotional ...
Origin Declaration authentication governs preferential tariff claims under India-UK CETA, requiring a validated reference number before import clearan...
Separate assessment orders for different years remain valid when distinct notices and hearing opportunities prevent prejudice from combined proceeding...
The article addresses whether pre-clinical R&D and testing services performed in India for foreign recipients qualify as export of services under the place-of-supply framework. It concludes that supplied samples/reference materials used in testing are not 'goods' attracting the place-of-performance exception, so the general place-of-supply rule applies and the location of the foreign recipient governs; consequently such services are not taxable in India when export conditions are met. It further finds that the clarificatory notification and amendment operate retrospectively as beneficial clarification, entitling the taxpayer to relief and justifying quashing of the impugned show-cause notices for the stated periods.
The article addresses whether pre-clinical R&D and testing services performed in India for foreign recipients qualify as export of services under the place-of-supply framework. It concludes that supplied samples/reference materials used in testing are not 'goods' attracting the place-of-performance exception, so the general place-of-supply rule applies and the location of the foreign recipient governs; consequently such services are not taxable in India when export conditions are met. It further finds that the clarificatory notification and amendment operate retrospectively as beneficial clarification, entitling the taxpayer to relief and justifying quashing of the impugned show-cause notices for the stated periods.
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