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    <title>2026 (5) TMI 1098 - CESTAT NEW DELHI</title>
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    <description>Un-invoiced allocations by a foreign parent to its Indian subsidiary were not taxable because they were shown as internal stewardship or shareholder ? No, avoid non-English. They were treated as expenses retained in the parent&#039;s books, not as services consumed by the Indian company, and no contractual service-provider relationship was established. The subsidiary had already paid service tax on invoiced allocations under reverse charge, but the disputed amounts were neither recorded in its books nor supported by evidence of actual service. Mere book entries, cost allocations, reimbursements, or internal apportionments did not create taxable service or consideration, so the demand, interest and penalties were not sustainable.</description>
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      <link>https://www.taxtmi.com/caselaws?id=791896</link>
      <description>Un-invoiced allocations by a foreign parent to its Indian subsidiary were not taxable because they were shown as internal stewardship or shareholder ? No, avoid non-English. They were treated as expenses retained in the parent&#039;s books, not as services consumed by the Indian company, and no contractual service-provider relationship was established. The subsidiary had already paid service tax on invoiced allocations under reverse charge, but the disputed amounts were neither recorded in its books nor supported by evidence of actual service. Mere book entries, cost allocations, reimbursements, or internal apportionments did not create taxable service or consideration, so the demand, interest and penalties were not sustainable.</description>
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