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...
Taxability of repairing activity undertaken by the appellant of transformers manufactured by other manufacturers - the tender process through which the appellant got the contract for repairing the transformers is only a "work order" and contract for repair and it is not a "maintenance contract". - Service Tax was not leviable during the relevant period - AT
Taxability of repairing activity undertaken by the appellant of transformers manufactured by other manufacturers - the tender process through which the appellant got the contract for repairing the transformers is only a "work order" and contract for repair and it is not a "maintenance contract". - Service Tax was not leviable during the relevant period - AT
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