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 - export of services - appellant’s services do not get covered under ITSS but fall under BAS which were taxable during the relevant period. Since, they have exported these services they are entitled to the benefit of the refund of the input service tax.
Refund - export of services - appellant’s services do not get covered under ITSS but fall under BAS which were taxable during the relevant period. Since, they have exported these services they are entitled to the benefit of the refund of the input service tax.
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