Transfer pricing adjustments for software services, corporate guarantees, expense characterisation and foreign tax credit affirmed under arm's length ...
Scientific Research approval for Sikshya O Anusandhan under section 35(1)(ii) granted subject to reporting, certification, and compliance requirements...
CESTAT held that the expression "transmission or distribution of electricity" has wide amplitude and covers services having a direct, proximate and integral nexus with that activity. On that basis, works contract services for erection, commissioning, installation and allied works, and manpower services used for movement, safeguarding and operational support, were treated as indispensable to electricity transmission and distribution and were not taxable under reverse charge. By contrast, rent-a-cab service for official use lacked the required direct nexus and was not exempt; however, the demand on that service was barred by limitation because mere non-payment or non-registration, without fraud, suppression or wilful misstatement, could not justify the extended period.
CESTAT held that the expression "transmission or distribution of electricity" has wide amplitude and covers services having a direct, proximate and integral nexus with that activity. On that basis, works contract services for erection, commissioning, installation and allied works, and manpower services used for movement, safeguarding and operational support, were treated as indispensable to electricity transmission and distribution and were not taxable under reverse charge. By contrast, rent-a-cab service for official use lacked the required direct nexus and was not exempt; however, the demand on that service was barred by limitation because mere non-payment or non-registration, without fraud, suppression or wilful misstatement, could not justify the extended period.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4817 
Join Channel 
