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 Service Tax paid under RCM - repeal of Finance Act and introduction of GST Act - rejection of refund on the ground that input tax credit can only be claimed under the GST/CGST Act, 2017 and not otherwise - the refund claims filed by the appellants should merit consideration under the provisions of sub-section (3) of section 142 ibid, and as such, it should be entitled for the benefit of refund of service tax paid by it. - AT
Refund of Service Tax paid under RCM - repeal of Finance Act and introduction of GST Act - rejection of refund on the ground that input tax credit can only be claimed under the GST/CGST Act, 2017 and not otherwise - the refund claims filed by the appellants should merit consideration under the provisions of sub-section (3) of section 142 ibid, and as such, it should be entitled for the benefit of refund of service tax paid by it. - AT
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