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...
Service tax demand on the basis of Form 26AS issued by the Income Tax Department - After considering the submissions, the Tribunal held that the demand based solely on Form 26AS was unsustainable. It noted the lack of examination of the appellant's records and the invocation of the extended period of limitation without proper investigation. Therefore, the demand was deemed not sustainable on limitation grounds.
Service tax demand on the basis of Form 26AS issued by the Income Tax Department - After considering the submissions, the Tribunal held that the demand based solely on Form 26AS was unsustainable. It noted the lack of examination of the appellant's records and the invocation of the extended period of limitation without proper investigation. Therefore, the demand was deemed not sustainable on limitation grounds.
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