Power to receive documentary evidence upheld; documents referred in complaint may be placed on record without amendment where omission was inadvertent...
Proof of foreign public documents requires originals or certified diplomatic/notarial copies; inspection must occur in-magna presence and cross-examin...
Prior Sanction Requirement: absence of prescribed approval invalidates reassessment notice; limitation also bars notice if escaped income below thresh...
Eligibility for exemption depends on strict construction of the product description; reapers without binder are ineligible, but confiscation and penal...
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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