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...
Taxability - liable to central excise duty or taxable under the provisions of the service tax for providing works contract service - Revenue failed to establish that the partially fabricated goods removed from the factory were in marketable state. The whole case is made out on the basis of assumptions and presumptions. No inspection has been made by the Revenue at the factory premises of the appellant/assessee - Appellant had taken registration under the Service Tax Provisions for discharge of their tax liability - Demand under central excise set aside - AT
Taxability - liable to central excise duty or taxable under the provisions of the service tax for providing works contract service - Revenue failed to establish that the partially fabricated goods removed from the factory were in marketable state. The whole case is made out on the basis of assumptions and presumptions. No inspection has been made by the Revenue at the factory premises of the appellant/assessee - Appellant had taken registration under the Service Tax Provisions for discharge of their tax liability - Demand under central excise set aside - AT
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