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...
Penalty u/s 78 of FA - there was a confusion at the field level for proper classification of activity undertaken by the appellant as to whether it is under ‘Business Auxiliary Service’ or under ‘Business Support Service’ and there have been multiplicity of interpretation - appellant had also deposited the entire amount of ST demanded under the SCN with interest before issuance of SCN - imposition of penalty u/s 78 is not warranted
Penalty u/s 78 of FA - there was a confusion at the field level for proper classification of activity undertaken by the appellant as to whether it is under ‘Business Auxiliary Service’ or under ‘Business Support Service’ and there have been multiplicity of interpretation - appellant had also deposited the entire amount of ST demanded under the SCN with interest before issuance of SCN - imposition of penalty u/s 78 is not warranted
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