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...
Power of commissioner to remand back the matter - As regards the ruling of Hon'ble Apex Court in MIL India Ltd. (2007 (3) TMI 8 - SUPREME COURT OF INDIA), the Hon'ble High Court observed that the Ruling is not applicable to Service Tax matters as sub-Section (5) of Section 85 of Finance Act, 1994 starts with words “subject to the provisions of this chapter” - AT
Power of commissioner to remand back the matter - As regards the ruling of Hon'ble Apex Court in MIL India Ltd. (2007 (3) TMI 8 - SUPREME COURT OF INDIA), the Hon'ble High Court observed that the Ruling is not applicable to Service Tax matters as sub-Section (5) of Section 85 of Finance Act, 1994 starts with words “subject to the provisions of this chapter” - AT
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