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    <title>2023 (11) TMI 311 - CESTAT AHMEDABAD</title>
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    <description>Professional fees and engineering charges received from foreign entities were treated as taxable consulting engineer services under the pre-2012 regime and import-of-service rules, so the demand was upheld. Corporate cost allocation for seconded employees was also held taxable because the substance of the arrangement showed continuing control with the foreign entity and the Indian recipient merely received the benefit of the deputed personnel. For various reimbursable and ancillary items, bank guarantee commission was held not taxable, several items were remanded for invoice-based verification, and specified expenses were sustained as part of taxable value or taxable foreign-currency es; books and magazine subscriptions were excluded. The extended limitation period was upheld because suppression and misstatement were found.</description>
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      <link>https://www.taxtmi.com/caselaws?id=445420</link>
      <description>Professional fees and engineering charges received from foreign entities were treated as taxable consulting engineer services under the pre-2012 regime and import-of-service rules, so the demand was upheld. Corporate cost allocation for seconded employees was also held taxable because the substance of the arrangement showed continuing control with the foreign entity and the Indian recipient merely received the benefit of the deputed personnel. For various reimbursable and ancillary items, bank guarantee commission was held not taxable, several items were remanded for invoice-based verification, and specified expenses were sustained as part of taxable value or taxable foreign-currency es; books and magazine subscriptions were excluded. The extended limitation period was upheld because suppression and misstatement were found.</description>
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