Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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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