Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Supply of Coursera user licences was held not to be an education service because the applicant only granted access to proprietary digital content and did not impart education, provide faculty, control curriculum, or assume instructional responsibility. Applying the specific-description principle, the supply was classified as a licensing service under Heading 9973, specifically SAC 997331, rather than Heading 9992 or Heading 9984. Because the supply was not an education service, the exemption under Sl. No. 72 of Notification No. 12/2017-Central Tax (Rate) was held inapplicable.
Supply of Coursera user licences was held not to be an education service because the applicant only granted access to proprietary digital content and did not impart education, provide faculty, control curriculum, or assume instructional responsibility. Applying the specific-description principle, the supply was classified as a licensing service under Heading 9973, specifically SAC 997331, rather than Heading 9992 or Heading 9984. Because the supply was not an education service, the exemption under Sl. No. 72 of Notification No. 12/2017-Central Tax (Rate) was held inapplicable.
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