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...
CENVAT Credit - input services, value of which not included in value of output services - As the receipts excluded from computation of assessable value are not consideration for exempt services or may even lie outside the scope of inclusion as consideration, by being returnable to the policy holder, the disputed ‘input services’ does not come within the ambit of rule 6 of CENVAT Credit Rules, 2004. - AT
CENVAT Credit - input services, value of which not included in value of output services - As the receipts excluded from computation of assessable value are not consideration for exempt services or may even lie outside the scope of inclusion as consideration, by being returnable to the policy holder, the disputed ‘input services’ does not come within the ambit of rule 6 of CENVAT Credit Rules, 2004. - AT
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