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...
Benefit of reduced penalty - penalty not deposited - get the benefit of reduced penalty of 25% of the service tax (ST) u/s 78(1) of the FA, 1994, assessee required to pay ST along with interest and deposits the 25% of penalty within a period of one month from the date of issue of determining order - Commissioner (Appeals) erred in reducing penalty at 25% from 100% of the ST demand without payment of the same
Benefit of reduced penalty - penalty not deposited - get the benefit of reduced penalty of 25% of the service tax (ST) u/s 78(1) of the FA, 1994, assessee required to pay ST along with interest and deposits the 25% of penalty within a period of one month from the date of issue of determining order - Commissioner (Appeals) erred in reducing penalty at 25% from 100% of the ST demand without payment of the same
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