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...
Best Judgement Assessment - It was incumbent upon the appellant to make available all the relevant documents to the Department even prior to the issuance of the show cause notice but that was not done and even in reply to the show cause notice no evidence had been produced by the appellant which may indicate that the service tax collected by the appellant, had been deposited with the Department. The only course open to the Department was to have initiated proceedings u/s 72 of the Finance Act and it did - Demand with penalty confirmed - AT
Best Judgement Assessment - It was incumbent upon the appellant to make available all the relevant documents to the Department even prior to the issuance of the show cause notice but that was not done and even in reply to the show cause notice no evidence had been produced by the appellant which may indicate that the service tax collected by the appellant, had been deposited with the Department. The only course open to the Department was to have initiated proceedings u/s 72 of the Finance Act and it did - Demand with penalty confirmed - AT
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