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 Service tax - royalty paid to M/s Unisys Corporation, USA - whether taxable under Intellectual Property Right Service or not? - Revenue failed to prove the IPR services. - Demand set aside.
Levy of Service tax - royalty paid to M/s Unisys Corporation, USA - whether taxable under Intellectual Property Right Service or not? - Revenue failed to prove the IPR services. - Demand set aside.
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