Allocation of registration charges: contractual clause overriding statutory presumption allowed as deduction against capital gain after unrebutted doc...
Expenditure tied to investments yielding exempt income restricted to attributable costs; broader disallowance disallowed and adjustments to WDV and mi...
Admissibility of Investigative Statements invalidated reliance on coerced emails and valuation redetermination, resulting in set aside of penalties an...
Classification of printed technical documents: specific Chapter 49.01 entry prevails, enabling claimed customs exemptions for imported manuals and rep...
Indian entity's education consultancy, marketing and recruitment support for foreign universities was held to be export of services, not intermediary service under the IGST Act. The decisive test was whether the contractual recipient and payer were the foreign universities and whether the supplier acted on its own account. Because the entity contracted with the universities, invoiced them, received consideration from them, did not charge students, had no authority to bind the universities, and could not guarantee admissions, incidental assistance to students in India did not convert it into an intermediary. The refund rejection was set aside and the refund was directed to be processed with statutory interest.
Indian entity's education consultancy, marketing and recruitment support for foreign universities was held to be export of services, not intermediary service under the IGST Act. The decisive test was whether the contractual recipient and payer were the foreign universities and whether the supplier acted on its own account. Because the entity contracted with the universities, invoiced them, received consideration from them, did not charge students, had no authority to bind the universities, and could not guarantee admissions, incidental assistance to students in India did not convert it into an intermediary. The refund rejection was set aside and the refund was directed to be processed with statutory interest.
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