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...
Penalty u/s 76 & 78 - ST was paid before SCN - appellant claim at it initially thought that service tax was not payable on commission as the service was received outside India, though untenable, cannot be held to be malafide. - Section 80 ibid is clearly invokable - penalty waived - AT
Penalty u/s 76 & 78 - ST was paid before SCN - appellant claim at it initially thought that service tax was not payable on commission as the service was received outside India, though untenable, cannot be held to be malafide. - Section 80 ibid is clearly invokable - penalty waived - AT
Note: It is a system-generated summary and is for quick reference only.