Transfer pricing comparability: one support-services company accepted, government-owned and facility-management comparables excluded, forex loss claim...
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Online training delivered through live and recorded digital platforms was classified as commercial training and coaching services under SAC 999293, because the supply was interactive, human-dependent, included live doubt-solving, structured guidance and printed study material, and was not mere online information access or retrieval. For place of supply, training services supplied to unregistered persons are governed by the location where the services are actually performed; since the coaching, technical infrastructure, faculty, content development, administration and dispatch of study material were all based in Rajasthan, the services were actually performed there. The supplies were therefore intra-State and taxable to CGST and Rajasthan SGST, not IGST, even where students were outside Rajasthan.
Online training delivered through live and recorded digital platforms was classified as commercial training and coaching services under SAC 999293, because the supply was interactive, human-dependent, included live doubt-solving, structured guidance and printed study material, and was not mere online information access or retrieval. For place of supply, training services supplied to unregistered persons are governed by the location where the services are actually performed; since the coaching, technical infrastructure, faculty, content development, administration and dispatch of study material were all based in Rajasthan, the services were actually performed there. The supplies were therefore intra-State and taxable to CGST and Rajasthan SGST, not IGST, even where students were outside Rajasthan.
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