Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
GST could not be levied again on a shipping line's ocean freight services for CIF imports where the freight component had already suffered customs duty in the import transaction, because the transportation service formed part of a composite supply. The Court held that taxing the same service element separately in the hands of the petitioner would amount to double taxation and would be inconsistent with the GST scheme. Relying on Union of India v. Mohit Minerals Pvt. Ltd., it found that transportation and insurance in a CIF contract are naturally bundled with the supply of goods. The show-cause notice and adjudication order were quashed, and refund with interest was directed.
GST could not be levied again on a shipping line's ocean freight services for CIF imports where the freight component had already suffered customs duty in the import transaction, because the transportation service formed part of a composite supply. The Court held that taxing the same service element separately in the hands of the petitioner would amount to double taxation and would be inconsistent with the GST scheme. Relying on Union of India v. Mohit Minerals Pvt. Ltd., it found that transportation and insurance in a CIF contract are naturally bundled with the supply of goods. The show-cause notice and adjudication order were quashed, and refund with interest was directed.
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