Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
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Reimbursements of wages paid to field consultants were held not includible in taxable value where they were mere pass-through amounts and tax had already been discharged on the service charge; the related demand was set aside. Diesel supplied under separate contracts was treated as a goods transaction, not part of the service value, so service tax on that component was unsustainable. Supply of soil by unit-based work order was not site formation service because it did not involve preparatory site activity. A demand based only on mismatch between ST-3 returns and balance sheet failed for want of evidence, and extended limitation was rejected as suppression was not proved. The demand, interest and penalties were set aside.
Reimbursements of wages paid to field consultants were held not includible in taxable value where they were mere pass-through amounts and tax had already been discharged on the service charge; the related demand was set aside. Diesel supplied under separate contracts was treated as a goods transaction, not part of the service value, so service tax on that component was unsustainable. Supply of soil by unit-based work order was not site formation service because it did not involve preparatory site activity. A demand based only on mismatch between ST-3 returns and balance sheet failed for want of evidence, and extended limitation was rejected as suppression was not proved. The demand, interest and penalties were set aside.
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