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...
Health Club & Fitness Centre - Assessee a hospital or not - obligation to show that the service provided by the appellant is a taxable service is on the Revenue and this basic obligation has not been fulfilled in this case. - AT
Health Club & Fitness Centre - Assessee a hospital or not - obligation to show that the service provided by the appellant is a taxable service is on the Revenue and this basic obligation has not been fulfilled in this case. - AT
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