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...
Recovery of service tax alongwith interest and penalty - Extended period of Limitation- The tribunal found that the appellant had disclosed their CENVAT credit in their tax returns, negating claims of willful suppression of facts. Furthermore, it was determined that the extended period of limitation was incorrectly applied by the authorities, as the issue of taxing renting of immovable property was under judicial scrutiny during the relevant period. Consequently, the tribunal allowed the appeal, setting aside the demand for service tax and penalties as barred by limitation.
Recovery of service tax alongwith interest and penalty - Extended period of Limitation- The tribunal found that the appellant had disclosed their CENVAT credit in their tax returns, negating claims of willful suppression of facts. Furthermore, it was determined that the extended period of limitation was incorrectly applied by the authorities, as the issue of taxing renting of immovable property was under judicial scrutiny during the relevant period. Consequently, the tribunal allowed the appeal, setting aside the demand for service tax and penalties as barred by limitation.
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