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...
Refund claim - Unjust enrichment - Chartered Accountant certificate indicates the bifurcation of the amounts towards maintenance charges and operation charges and has specifically certified assessee has not passed on the service tax liability on the operations part to any one and has borne the burden of the service tax - refund allowed - AT
Refund claim - Unjust enrichment - Chartered Accountant certificate indicates the bifurcation of the amounts towards maintenance charges and operation charges and has specifically certified assessee has not passed on the service tax liability on the operations part to any one and has borne the burden of the service tax - refund allowed - AT
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