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...
Extended period of limitation - in all the letters issued by the appellant to the department, they have given the details of the payments made and also clarified that they are making the payments in accordance with Slump Sale Agreement - the appellant cannot be saddled with the guilt of suppression of facts with intention to evade payment of service tax.
Extended period of limitation - in all the letters issued by the appellant to the department, they have given the details of the payments made and also clarified that they are making the payments in accordance with Slump Sale Agreement - the appellant cannot be saddled with the guilt of suppression of facts with intention to evade payment of service tax.
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