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...
Classification of services - The Tribunal established that amounts received as incentives, productivity-linked bonuses, and boarding incentives from airlines are taxable under the category of "Air Travel Agent Services" and not under BAS. It was also held that commissions received from other travel agents or General Sales Agents (GSAs) and from the appellant's own branches do not constitute taxable services under BAS. - AT
Classification of services - The Tribunal established that amounts received as incentives, productivity-linked bonuses, and boarding incentives from airlines are taxable under the category of "Air Travel Agent Services" and not under BAS. It was also held that commissions received from other travel agents or General Sales Agents (GSAs) and from the appellant's own branches do not constitute taxable services under BAS. - AT
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