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 - Business Auxiliary Services (BAS) or not - The Tribunal while seting aside the demand, held that, the Revenue having alleged that the services rendered by the appellant were under BAS, has not bothered to specifically identify the limb provided under various sub-clauses under the definition of BAS. Unless the alleged service is brought under the specific limb provided under the statute, Service Tax cannot be demanded under BAS as such, since BAS is an umbrella under which various services are categorized.
Classification of services - Business Auxiliary Services (BAS) or not - The Tribunal while seting aside the demand, held that, the Revenue having alleged that the services rendered by the appellant were under BAS, has not bothered to specifically identify the limb provided under various sub-clauses under the definition of BAS. Unless the alleged service is brought under the specific limb provided under the statute, Service Tax cannot be demanded under BAS as such, since BAS is an umbrella under which various services are categorized.
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