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...
Denial of refund claim - Unjust enrichment - service tax element was shown in the invoices but the same was not paid by the service recipient - Appellant discharged its onus that excess service tax paid has not been recovered from the customers - refund allowed - AT
Denial of refund claim - Unjust enrichment - service tax element was shown in the invoices but the same was not paid by the service recipient - Appellant discharged its onus that excess service tax paid has not been recovered from the customers - refund allowed - AT
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