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...
Reverse charge mechanism (RCM) - non-payment of service tax - the service tax on all the above services was available as credit to the appellant, thus leading to a Revenue neutral situation in which case again no mala fide can be attributed and demands cannot be sustained.
Reverse charge mechanism (RCM) - non-payment of service tax - the service tax on all the above services was available as credit to the appellant, thus leading to a Revenue neutral situation in which case again no mala fide can be attributed and demands cannot be sustained.
Note: It is a system-generated summary and is for quick reference only.
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