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 on franchisee and royalty fee paid to their US based franchiser - sharing of compensation - prima facie the appellants are liable to pay service tax on the amount remitted to the overseas franchisee as per the agreement. - AT
Levy of service tax on franchisee and royalty fee paid to their US based franchiser - sharing of compensation - prima facie the appellants are liable to pay service tax on the amount remitted to the overseas franchisee as per the agreement. - AT
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