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...
Valuation - sale of Recharge Vouchers and SIM Cards - Respondents have discharged the service tax liability on the basis of MRP to the ultimate subscribers after the Recharge Vouchers and SIM Cards as and when sold directly to the subscribers; the respondent also discharged the service tax liability on the actual amount received by them from the distributors and dealers for the sale of Recharge Vouchers and SIM Cards from such distributors and dealers - demand set aside - AT
Valuation - sale of Recharge Vouchers and SIM Cards - Respondents have discharged the service tax liability on the basis of MRP to the ultimate subscribers after the Recharge Vouchers and SIM Cards as and when sold directly to the subscribers; the respondent also discharged the service tax liability on the actual amount received by them from the distributors and dealers for the sale of Recharge Vouchers and SIM Cards from such distributors and dealers - demand set aside - AT
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