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 penalty - The service tax collected if not deposited with the government automatically leads to an inference that there was an intention on the part of the appellant to evade the tax - benefit of Section 73(3) not available - penalty confirmed - AT
Levy of penalty - The service tax collected if not deposited with the government automatically leads to an inference that there was an intention on the part of the appellant to evade the tax - benefit of Section 73(3) not available - penalty confirmed - AT
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