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...
Export of services - Procedural lapse in submitting the proof of documents - Non-fulfilment of conditions prescribed in the N/N. 18/2009-ST - After hearing both sides, the Tribunal observed that the sole ground for confirming the demand was the non-fulfillment of conditions specified in the Notification. However, considering the explanations provided and the subsequent submission of documents by the appellant, the Court concluded that denial of exemption due to procedural lapses was unjustified.
Export of services - Procedural lapse in submitting the proof of documents - Non-fulfilment of conditions prescribed in the N/N. 18/2009-ST - After hearing both sides, the Tribunal observed that the sole ground for confirming the demand was the non-fulfillment of conditions specified in the Notification. However, considering the explanations provided and the subsequent submission of documents by the appellant, the Court concluded that denial of exemption due to procedural lapses was unjustified.
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