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...
Units in SEZ and DTA Seperate legal entity or not - In the case of service tax levy, presence of two persons is a must and these persons have necessarily to be legal persons since there is no definition of person in the Service Tax Act which would mean person has to be understood the way it is understood otherwise - AT
Units in SEZ and DTA Seperate legal entity or not - In the case of service tax levy, presence of two persons is a must and these persons have necessarily to be legal persons since there is no definition of person in the Service Tax Act which would mean person has to be understood the way it is understood otherwise - AT
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