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...
Valuation - inclusion of value of materials supplied by the respondent under a separate material supply contract with EDAs in the gross value of Works Contract Service - Rule 3 of Works Contract (Composition Scheme for payment of Service tax) Rules, 2007 - If the contention of the revenue is accepted it will amount to give retrospective effect to the amendment of 07.07.2009 which is not permissible under law - AT
Valuation - inclusion of value of materials supplied by the respondent under a separate material supply contract with EDAs in the gross value of Works Contract Service - Rule 3 of Works Contract (Composition Scheme for payment of Service tax) Rules, 2007 - If the contention of the revenue is accepted it will amount to give retrospective effect to the amendment of 07.07.2009 which is not permissible under law - AT
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