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...
Non-payment of service tax - difference between the statutory returns and the annual balance sheet - The burden of explaining the difference amount being not taxable income has been shifted to the appellant. This will be against the very basis of tax levy - AT
Non-payment of service tax - difference between the statutory returns and the annual balance sheet - The burden of explaining the difference amount being not taxable income has been shifted to the appellant. This will be against the very basis of tax levy - AT
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