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...
Refund of Service Tax - Unjust enrichment - the service tax for the period in question was deposited by the petitioner but after realizing it from its customers and no refund application was filed by these customers - if the burden of the service tax has been shifted on the customers, the petitioner can not be a beneficiary thereof as any refund which would amount to unjust enrichment
Refund of Service Tax - Unjust enrichment - the service tax for the period in question was deposited by the petitioner but after realizing it from its customers and no refund application was filed by these customers - if the burden of the service tax has been shifted on the customers, the petitioner can not be a beneficiary thereof as any refund which would amount to unjust enrichment
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