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...
Demand of service tax on the interest earned from hire purchase finance transactions. - The Tribunal observes that the ownership of the goods remains with the customers, and the Appellant only finances the purchase. There is no clause providing customers an option to purchase the product at the end of payment of all installments. Relying on the Supreme Court's decision, the Tribunal distinguishes between hire purchase agreements and hire purchase finance agreements. - Demand set aside.
Demand of service tax on the interest earned from hire purchase finance transactions. - The Tribunal observes that the ownership of the goods remains with the customers, and the Appellant only finances the purchase. There is no clause providing customers an option to purchase the product at the end of payment of all installments. Relying on the Supreme Court's decision, the Tribunal distinguishes between hire purchase agreements and hire purchase finance agreements. - Demand set aside.
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