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...
Section 43B is applicable in the case of sales tax and excise duty but same could not be in case of service tax: CIT (A) held that assessee never allowed deduction on account of service tax which is collected on behalf of government and paid to government account, therefore service provider is merely acting as the agent of the government and is not entitled to deduction on account of service tax. - AT
Section 43B is applicable in the case of sales tax and excise duty but same could not be in case of service tax: CIT (A) held that assessee never allowed deduction on account of service tax which is collected on behalf of government and paid to government account, therefore service provider is merely acting as the agent of the government and is not entitled to deduction on account of service tax. - AT
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