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...
Exemption from Service Tax - Advertisement Agency Service - Selling of Space - The Tribunal held that the appellant's activities did not constitute 'Advertising Agency' services but were correctly classified under 'selling of space for advertisement', which was not taxable during the specified period. Consequently, penalties under Section 78 on the firm and Section 78A on the partner were also set aside, granting relief to the appellant.
Exemption from Service Tax - Advertisement Agency Service - Selling of Space - The Tribunal held that the appellant's activities did not constitute 'Advertising Agency' services but were correctly classified under 'selling of space for advertisement', which was not taxable during the specified period. Consequently, penalties under Section 78 on the firm and Section 78A on the partner were also set aside, granting relief to the appellant.
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