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...
Refund of cenvat credit - export of non-taxable servcies - Decision in the case of mPortal India Wireless Solutions.(P) Ltd [2011 (9) TMI 450 - KARNATAKA HIGH COURT] and [2010 (7) TMI 92 - CESTAT, BANGALORE] distinguished. - Refund denied - AT
Refund of cenvat credit - export of non-taxable servcies - Decision in the case of mPortal India Wireless Solutions.(P) Ltd [2011 (9) TMI 450 - KARNATAKA HIGH COURT] and [2010 (7) TMI 92 - CESTAT, BANGALORE] distinguished. - Refund denied - AT
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