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...
Demand of service tax prior to 1.6.2007 - Works contract for Delhi Metro Rail (DMRC) - the reasoning and conclusion by the ld. Adjudicating authority that only works contracts pertaining to constructing of railway lines for railways is excluded is clearly erroneous and amounts to legislation rather than adjudication on a true , fair and good faith of interpretation of the provision - AT
Demand of service tax prior to 1.6.2007 - Works contract for Delhi Metro Rail (DMRC) - the reasoning and conclusion by the ld. Adjudicating authority that only works contracts pertaining to constructing of railway lines for railways is excluded is clearly erroneous and amounts to legislation rather than adjudication on a true , fair and good faith of interpretation of the provision - AT
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