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...
Erection, commissioning or installation service - Since the appellant admittedly provide works contract service and the definition of works contract service specifically excludes railway from its purview for levy of Service Tax, the activities provided pursuant to the contract even after 01.06.2007 cannot be taxed under the work contract service. - AT
Erection, commissioning or installation service - Since the appellant admittedly provide works contract service and the definition of works contract service specifically excludes railway from its purview for levy of Service Tax, the activities provided pursuant to the contract even after 01.06.2007 cannot be taxed under the work contract service. - AT
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