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...
Applicability of exemption notification - Construction services - services to GDA, U.P. Jal-Nigam and other Government Authorities - construction of 33 and 11 KVA electric substations at Indirapuram, it is also related to transmission of electricity covered by negative list after 01.07.2012 - cover by N.No.45/2010-ST dated 20.07.2010 and N.No..11/2010-ST dated 27.02.2010, the ST & penalty is not sustainable
Applicability of exemption notification - Construction services - services to GDA, U.P. Jal-Nigam and other Government Authorities - construction of 33 and 11 KVA electric substations at Indirapuram, it is also related to transmission of electricity covered by negative list after 01.07.2012 - cover by N.No.45/2010-ST dated 20.07.2010 and N.No..11/2010-ST dated 27.02.2010, the ST & penalty is not sustainable
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