TMI Blog2013 (10) TMI 1325X X X X Extracts X X X X X X X X Extracts X X X X ..... ls, who are provided the specialised diabetes management training who are the recipients of the commercial training or coaching service, provided by the petitioner. In the absence of such nexus, the inference in the adjudication order that the donations must be included in the gross taxable value for taxable services provided by the petitioner, is prima facie unsustainable, in view of the Board Ci ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... harmaceuticals Pvt. Ltd. and from the Ministry of Health and Family Welfare as part of taxable value received for providing the taxable Commercial Training or Coaching service. 2. Before the adjudicating authority, petitioner relied on the Board Circular No. 127/09/2010-S.T., dated 16-8-2010, which clarifies that grants-in-aid received from different sources by charitable foundations cannot b ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the grants/donations to the petitioner either from M/s. MSD Pharmaceuticals Pvt. Ltd. or from Govt. Departments and medical professionals, who are provided the specialised diabetes management training who are the recipients of the commercial training or coaching service, provided by the petitioner. In the absence of such nexus, the inference in the adjudication order that the donations must be inc ..... X X X X Extracts X X X X X X X X Extracts X X X X
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