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 rebate of Service Tax - no nexus between the input services and the exported output service - There is no clear proposition or proposal for this in the show cause notice. In the absence of a clear proposal, the ground of nexus to reject the rebate claim of tax paid on output service could not have been used - AT
Denial of rebate of Service Tax - no nexus between the input services and the exported output service - There is no clear proposition or proposal for this in the show cause notice. In the absence of a clear proposal, the ground of nexus to reject the rebate claim of tax paid on output service could not have been used - AT
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