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...
Demand of service tax - GTA - it is settled that the goods for the purpose of Goods Transport Agency service should be qualified as "goods‟ in terms of definition given under Section 65(50) of Finance Act, 1994. Therefore, in the present case the goods being effluent which is neither sold nor saleable, does not qualify in terms “goods”. Therefore, transportation of the same does not fall under the four corners of Goods Transport Agency service, hence the same is not liable to service tax - AT
Demand of service tax - GTA - it is settled that the goods for the purpose of Goods Transport Agency service should be qualified as "goods‟ in terms of definition given under Section 65(50) of Finance Act, 1994. Therefore, in the present case the goods being effluent which is neither sold nor saleable, does not qualify in terms “goods”. Therefore, transportation of the same does not fall under the four corners of Goods Transport Agency service, hence the same is not liable to service tax - AT
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