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...
Non-payment of service tax - reverse charge mechanism (RCM) - amount paid to the Government or a local authority - right to use of natural resource or quarry sand from the allotted mines - The Point of Taxation Rules deal with the date on which payment of service tax has to be made and do not determine whether the service is taxable or not. These Rules, therefore, would not be applicable in the present case. - AT
Non-payment of service tax - reverse charge mechanism (RCM) - amount paid to the Government or a local authority - right to use of natural resource or quarry sand from the allotted mines - The Point of Taxation Rules deal with the date on which payment of service tax has to be made and do not determine whether the service is taxable or not. These Rules, therefore, would not be applicable in the present case. - AT
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