Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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 Cenvat credit - export of service - benefit was accrued in India - the place of provision of service will more appropriately be categorized under Rule 3 ibid inasmuch as the service recipient has its business establishment in United Kingdom and thus, the place of provision of service is outside India, which would be considered as export of service for grant of refund of service tax paid on the input services. - AT
Refund of Cenvat credit - export of service - benefit was accrued in India - the place of provision of service will more appropriately be categorized under Rule 3 ibid inasmuch as the service recipient has its business establishment in United Kingdom and thus, the place of provision of service is outside India, which would be considered as export of service for grant of refund of service tax paid on the input services. - AT
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