Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
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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