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...
GTA Service - denial of benefit of 75% abatement in the absence of any declaration furnished by the transport agencies - There is no merit in the submissions that even without declaration as stipulated in the notification, the assessee was entitled to such exemption, is over simplifying or glossing over the conditions itself, which cannot be permitted. - Tribunal was perfectly justified in denying such exemption.
GTA Service - denial of benefit of 75% abatement in the absence of any declaration furnished by the transport agencies - There is no merit in the submissions that even without declaration as stipulated in the notification, the assessee was entitled to such exemption, is over simplifying or glossing over the conditions itself, which cannot be permitted. - Tribunal was perfectly justified in denying such exemption.
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