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...
Classification of service - appellants had been appointed as custodian of imported edible oils under Customs Act, 1962 and had rented/leased out their storage tanks in Kakinada for storage of the imported edible oils to those importers who availed the facility of storing imported oils in these storage tanks - appellant herein would not qualify for taxing under ‘storage and warehousing services.
Classification of service - appellants had been appointed as custodian of imported edible oils under Customs Act, 1962 and had rented/leased out their storage tanks in Kakinada for storage of the imported edible oils to those importers who availed the facility of storing imported oils in these storage tanks - appellant herein would not qualify for taxing under ‘storage and warehousing services.
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