Debate Over Classification of Broadcasting vs. Intermediary Services for Tax Purposes; No Outflow to Overseas Entity.

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....BAS - Broadcasting Service or intermediary service - Import of services - Place of provision of services - respondents are ‘surrogate’ providers of ‘broadcasting’ service in India - The retained amount is not an outflow and, in the absence of outflow of consideration from the respondents herein to the overseas entity, recourse to these Rules cannot be had.....