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...
Classification of services - manpower recruitment or supply agency service, or not - The contract is relating to the handling and transportation of coal. - The work that was given to the appellant was for unloading, transportation and stacking of coal from the railway wagons to the coal yard and the documents available in the appeal indicate that there is no agreement for supply of manpower to the recipient of service - The services rendered by the appellant cannot be classified under the category of “manpower recruitment or supply agency” service - AT
Classification of services - manpower recruitment or supply agency service, or not - The contract is relating to the handling and transportation of coal. - The work that was given to the appellant was for unloading, transportation and stacking of coal from the railway wagons to the coal yard and the documents available in the appeal indicate that there is no agreement for supply of manpower to the recipient of service - The services rendered by the appellant cannot be classified under the category of “manpower recruitment or supply agency” service - AT
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