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...
Levy of Service tax - Business auxiliary service - commission retained/earned towards the service rendered by them to the co-GSA/IATA - The Tribunal finds that the appellant's activities do not fall under "Business Auxiliary Services" as alleged by the revenue. It determines that the appellants act as principal-to-principal in their transactions and do not serve as commission agents for other GSA/IATA operators. - Further, the Tribunal agrees with the appellant's argument that it was issued beyond the prescribed period and finds no evidence of suppression or intent to evade tax.
Levy of Service tax - Business auxiliary service - commission retained/earned towards the service rendered by them to the co-GSA/IATA - The Tribunal finds that the appellant's activities do not fall under "Business Auxiliary Services" as alleged by the revenue. It determines that the appellants act as principal-to-principal in their transactions and do not serve as commission agents for other GSA/IATA operators. - Further, the Tribunal agrees with the appellant's argument that it was issued beyond the prescribed period and finds no evidence of suppression or intent to evade tax.
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