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...
Levy of service tax - Appellant claimed that NIXI is not the ISP (internet service provider) - a single transaction of providing peering cannot be split into two transactions, nor is it permissible to artificially vivisect a composite indivisible commercial transaction and examine one part for taxability purposes. - AT
Levy of service tax - Appellant claimed that NIXI is not the ISP (internet service provider) - a single transaction of providing peering cannot be split into two transactions, nor is it permissible to artificially vivisect a composite indivisible commercial transaction and examine one part for taxability purposes. - AT
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