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...
Levy of GST and Service tax - coaching provided by the applicant to its students - it cannot be said that the coaching / training given by the applicant to CA aspiring students (for appearing and qualifying in the examinations) would lead to grant of certificate/qualification recognized by law. Therefore, the service rendered by the applicant is Not a service by way of ‘education as a part of curriculum for obtaining a qualification recognized by any law for the time being in force’.
Levy of GST and Service tax - coaching provided by the applicant to its students - it cannot be said that the coaching / training given by the applicant to CA aspiring students (for appearing and qualifying in the examinations) would lead to grant of certificate/qualification recognized by law. Therefore, the service rendered by the applicant is Not a service by way of ‘education as a part of curriculum for obtaining a qualification recognized by any law for the time being in force’.
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