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...
Valuation of services - support services of business or commerce [BSS] or not - treatment of mark up, being, difference between the amount paid by the Appellant to the Shipping Lines/Airlines - The decision in D. Pauls Consumer Benefit Ltd. [2017 (3) TMI 1019 - CESTAT NEW DELHI] was overruled by Larger Bench of the Tribunal in Kafila Hospitality & Travels Pvt. Ltd. v/s Commissioner, Service Tax, Delhi 2021 (3) TMI 773 - CESTAT NEW DELHI] - Demand set aside - AT
Valuation of services - support services of business or commerce [BSS] or not - treatment of mark up, being, difference between the amount paid by the Appellant to the Shipping Lines/Airlines - The decision in D. Pauls Consumer Benefit Ltd. [2017 (3) TMI 1019 - CESTAT NEW DELHI] was overruled by Larger Bench of the Tribunal in Kafila Hospitality & Travels Pvt. Ltd. v/s Commissioner, Service Tax, Delhi 2021 (3) TMI 773 - CESTAT NEW DELHI] - Demand set aside - AT
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