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...
Rent-a-cab service - allegation that they have deliberately suppressed the material facts with intent to evade payment of service tax - The appellant providing several numbers of vehicles to BSNL etc. on monthly basis against considerations which otherwise are on yearly basis. Also keeping in view the appellant is admittedly registered as rent-a-cab service provider, we hereby answer the question so framed in affirmative i.e. in favour of revenue. - AT
Rent-a-cab service - allegation that they have deliberately suppressed the material facts with intent to evade payment of service tax - The appellant providing several numbers of vehicles to BSNL etc. on monthly basis against considerations which otherwise are on yearly basis. Also keeping in view the appellant is admittedly registered as rent-a-cab service provider, we hereby answer the question so framed in affirmative i.e. in favour of revenue. - AT
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