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...
Levy of service tax - Reverse charge mechanism - Revenue neutrality since cenvat credit is available - unable to locate any statutory or constitutional provisions which support the notion that in case of revenue neutrality the liability to tax abates. - Prima facie case is against the assessee - AT
Levy of service tax - Reverse charge mechanism - Revenue neutrality since cenvat credit is available - unable to locate any statutory or constitutional provisions which support the notion that in case of revenue neutrality the liability to tax abates. - Prima facie case is against the assessee - AT
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