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...
Extended period of limitation - Recovery of service tax - service being taxable but the liability has not been discharged by the appellant - the Department has wrongly invoked the extended period of limitation. - nothing of this sort is apparent on part of the appellant - Department has wrongly invoked the extended period of limitation. Both the SCNs are therefore, held to be barred by the period of limitation. - AT
Extended period of limitation - Recovery of service tax - service being taxable but the liability has not been discharged by the appellant - the Department has wrongly invoked the extended period of limitation. - nothing of this sort is apparent on part of the appellant - Department has wrongly invoked the extended period of limitation. Both the SCNs are therefore, held to be barred by the period of limitation. - AT
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