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...
Refund claim - service tax paid on technical inspection and certification services, much before 01.07.2017 - Post GST era - The observation made by the Commissioner (Appeals) in respect of the provisions of Section 173 of The Central Goods and Service Tax Act, 2017, are in respect of the repeal of notification 41/2012-ST without even referring to the Section 1 74 (2) ibid, cannot impact the rights accrued to the appellant prior to such repeal. - AT
Refund claim - service tax paid on technical inspection and certification services, much before 01.07.2017 - Post GST era - The observation made by the Commissioner (Appeals) in respect of the provisions of Section 173 of The Central Goods and Service Tax Act, 2017, are in respect of the repeal of notification 41/2012-ST without even referring to the Section 1 74 (2) ibid, cannot impact the rights accrued to the appellant prior to such repeal. - AT
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