Question ID :
Export of Services
1. Can Rule 6A(f) be read with Item (b) of Explanation 3 under Clause 44 of Section 65B to interpret that supply of services by a wholly-owned Indian (private limited) subsidiary company (WOS) to its overseas holding company is not an export?
2. Is it fair to interpret that a WOS and holding company are merely establishments of a person?
3. Is Explanation 4 to 65B(44) not exhaustive when it says that branch, agency or representation office (3 instances) are considered mere establishments of a person?
4. How can an Indian subsidiary be treated as a mere establishment of its overseas holding company when companies have separate legal identity?
CA VISHRANT SHUKLA
Aug 29, 2018