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...
Refund of the service tax paid - Period of limitation - They have filed the refund claim well in time with KMDA with whom they paid the service tax. As the Notification 41/2016 was not clear with whom the refund application was to be filed, the delay has happened. Thus, the delay in filing the refund application with the service tax department was not due to the fault of the Appellant. - AT
Refund of the service tax paid - Period of limitation - They have filed the refund claim well in time with KMDA with whom they paid the service tax. As the Notification 41/2016 was not clear with whom the refund application was to be filed, the delay has happened. Thus, the delay in filing the refund application with the service tax department was not due to the fault of the Appellant. - AT
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