https://www.taxtmi.com/caselaws?id=294988 A binding later agreement with an entire-agreement clause superseded the earlier arrangement, so the foreign service provider's role was classified by its predominant character as underwriting under Section 65A(c), not as merchant banking. The service tax demand also failed because the transaction was completed outside India and the consideration was paid by appropriation from issue proceeds rather than remittance from India, leaving the taxing conditions unsatisfied. The demand was therefore unsustainable on both classification and territorial jurisdiction grounds. en-us Thu, 31 Jan 2019 00:00:00 +0530 Fri, 14 May 2021 08:32:11 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=294988 A binding later agreement with an entire-agreement clause superseded the earlier arrangement, so the foreign service provider's role was classified by its predominant character as underwriting under Section 65A(c), not as merchant banking. The service tax demand also failed because the transaction was completed outside India and the consideration was paid by appropriation from issue proceeds rather than remittance from India, leaving the taxing conditions unsatisfied. The demand was therefore unsustainable on both classification and territorial jurisdiction grounds. Case-Laws Service Tax Thu, 31 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=294988