Subsidiary & its parent company located in different taxable territories are distinct entities

Zaloni Technologies India Private Limited Vs Commissioner of Central Excise & Service Tax (CESTAT Kolkata) Hon’ble Supreme Court in the case of Vodafone International Holdings B.V. Vs. Union of India [2012 (6) S.C.C. 613] has held that a subsidiary and its parent company located in different taxable territories are totally distinct taxpayer (s) or different entities. Further, the Hon’ble Gujarat High Court in the case of Linde Engineering India Pvt. Ltd. (supra) has held that explanation 3(b) under Clause (44) of Section 65B has been considered and it has been held that service provide...