Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Goods Transport Agency classification does not depend on a document being expressly titled a consignment note. Bills containing essential transportation particulars may qualify as consignment notes, and recipients' certificates confirming receipt of GTA services and reverse-charge tax payment support that classification. Service tax demands cannot rest solely on differences between ST-3 returns and Form 26AS or other Income Tax data without verification of books of account and underlying transactions, because such data do not determine taxable turnover under service tax law. Extended limitation cannot be invoked for alleged suppression where relevant facts were already available to the Department and ST-3 returns were regularly filed. The impugned demands were set aside with consequential relief.
Goods Transport Agency classification does not depend on a document being expressly titled a consignment note. Bills containing essential transportation particulars may qualify as consignment notes, and recipients' certificates confirming receipt of GTA services and reverse-charge tax payment support that classification. Service tax demands cannot rest solely on differences between ST-3 returns and Form 26AS or other Income Tax data without verification of books of account and underlying transactions, because such data do not determine taxable turnover under service tax law. Extended limitation cannot be invoked for alleged suppression where relevant facts were already available to the Department and ST-3 returns were regularly filed. The impugned demands were set aside with consequential relief.
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