Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Where a single contract separately itemises remuneration for Clearing & Forwarding (C&F) services and transportation, the services are distinct; transportation qualifies as Goods Transport Agency (GTA) services and attracts reverse charge liability on the service recipient. Applying statutory scheme and Service Tax Rules, Rule 2(1)(d)(d), transportation charges expressly stated for GTA cannot be included in the assessable value of C&F services to avoid double taxation. The tribunal applied prior authorities and administrative instructions and set aside the demand, holding that separately charged GTA consideration is outside C&F taxable value.
Where a single contract separately itemises remuneration for Clearing & Forwarding (C&F) services and transportation, the services are distinct; transportation qualifies as Goods Transport Agency (GTA) services and attracts reverse charge liability on the service recipient. Applying statutory scheme and Service Tax Rules, Rule 2(1)(d)(d), transportation charges expressly stated for GTA cannot be included in the assessable value of C&F services to avoid double taxation. The tribunal applied prior authorities and administrative instructions and set aside the demand, holding that separately charged GTA consideration is outside C&F taxable value.
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