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 on the basis of 26AS (TDS statement) - Extended period of limitation - the figures reflected in Form 26AS cannot be used to determine Service Tax liability unless there is evidence shown that it was due to a taxable service - thus, the entire demand has been raised beyond the normal period of limitation. - Demand set aside - AT
Demand of service tax on the basis of 26AS (TDS statement) - Extended period of limitation - the figures reflected in Form 26AS cannot be used to determine Service Tax liability unless there is evidence shown that it was due to a taxable service - thus, the entire demand has been raised beyond the normal period of limitation. - Demand set aside - AT
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