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 - The appellant alternatively claimed the benefit of Section 73 (3) of finance Act, 1994 on the ground that the entire service tax along with interest paid prior to show cause notice. Considering this position the demand for extended period is not sustainable hence the same is set aside. Demand for the normal period if any, is sustained along with interest. - AT
Extended Period of Limitation - The appellant alternatively claimed the benefit of Section 73 (3) of finance Act, 1994 on the ground that the entire service tax along with interest paid prior to show cause notice. Considering this position the demand for extended period is not sustainable hence the same is set aside. Demand for the normal period if any, is sustained along with interest. - AT
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