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 services - Franchise services or not - slump sale of business of marketing - None of the ingredients of franchisee service or the Board Circular are present in the BPA between the Appellant and M/s Aventis - the Appellants do not qualify as Franchisor as the trademarks have been permanently assigned to M/s Aventis and they have become absolute owner with no control of the Appellant - no service tax
Classification of services - Franchise services or not - slump sale of business of marketing - None of the ingredients of franchisee service or the Board Circular are present in the BPA between the Appellant and M/s Aventis - the Appellants do not qualify as Franchisor as the trademarks have been permanently assigned to M/s Aventis and they have become absolute owner with no control of the Appellant - no service tax
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