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Pre-commencement R&D deduction denied where business had not commenced; deeming benefit requires tangible start of manufacture or commercial exploitat...
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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