Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
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Pigmy agents engaged by a bank were treated as employees because the relationship was marked by pervasive control, supervision and disciplinary oversight, with commission functioning in substance as wages. Their services rendered in the course of employment fell within Schedule III read with section 7(2)(a) of the GST law and were therefore neither a supply of goods nor a supply of services. The attempt to classify them as business facilitators liable under reverse charge was rejected, and the show cause notices were quashed for proceeding on an erroneous jurisdictional basis. The challenge to the limitation-extension notifications was left open.
Pigmy agents engaged by a bank were treated as employees because the relationship was marked by pervasive control, supervision and disciplinary oversight, with commission functioning in substance as wages. Their services rendered in the course of employment fell within Schedule III read with section 7(2)(a) of the GST law and were therefore neither a supply of goods nor a supply of services. The attempt to classify them as business facilitators liable under reverse charge was rejected, and the show cause notices were quashed for proceeding on an erroneous jurisdictional basis. The challenge to the limitation-extension notifications was left open.
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