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...
Extended period of limitation - it is found that appellant were under the bonafide belief that no service tax was payable on the brokerage received by them for providing steamer agent service being a sub-agent - also, all the transactions between the appellant and M/s. Freight Connection India Pvt. Limited are recorded in the books of accounts - extended time to demand service tax under Section 73 is not invokable. - AT
Extended period of limitation - it is found that appellant were under the bonafide belief that no service tax was payable on the brokerage received by them for providing steamer agent service being a sub-agent - also, all the transactions between the appellant and M/s. Freight Connection India Pvt. Limited are recorded in the books of accounts - extended time to demand service tax under Section 73 is not invokable. - AT
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