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 penalty - retrospective exemption from service tax with interest - refund rejected on the ground that the notification exempted only service tax and interest thereon and not penalty. - Penalty amount directed to be refunded.
Refund of penalty - retrospective exemption from service tax with interest - refund rejected on the ground that the notification exempted only service tax and interest thereon and not penalty. - Penalty amount directed to be refunded.
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