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...
Waiver of penalty u/s 80 - the assessee will have to demonstrate that there are reasonable grounds to suggest that the amount received as a Subcontractor is not liable for the service tax. Mere assumption is not sufficient - Penalty cannot be set aside
Waiver of penalty u/s 80 - the assessee will have to demonstrate that there are reasonable grounds to suggest that the amount received as a Subcontractor is not liable for the service tax. Mere assumption is not sufficient - Penalty cannot be set aside
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