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 - activity of preparation of site for the power plant - It has been found as a fact that the work order in the present case, involves both supply of services as also goods. It is, therefore, a composite contract. In view of the decisions of the Supreme Court in Larsen & Toubro it has to be held that the services performed by the appellant under the work order would fall in the category of “works contract‘ service and not “site formation‘ service. - AT
Classification of services - activity of preparation of site for the power plant - It has been found as a fact that the work order in the present case, involves both supply of services as also goods. It is, therefore, a composite contract. In view of the decisions of the Supreme Court in Larsen & Toubro it has to be held that the services performed by the appellant under the work order would fall in the category of “works contract‘ service and not “site formation‘ service. - AT
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