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 service - Business Support services or not - The Appellate Tribunal, referring to precedent cases, concluded that GTPL's activity of arranging transportation did not qualify as business support service. They emphasized that GTPL solely organized transportation without providing loading/unloading or other logistics services. The tribunal found no evidence of a contract for the provision of business support service between GTPL and their buyers. Therefore, they dismissed the revenue's claim regarding the nature of the service provided by GTPL.
Classification of service - Business Support services or not - The Appellate Tribunal, referring to precedent cases, concluded that GTPL's activity of arranging transportation did not qualify as business support service. They emphasized that GTPL solely organized transportation without providing loading/unloading or other logistics services. The tribunal found no evidence of a contract for the provision of business support service between GTPL and their buyers. Therefore, they dismissed the revenue's claim regarding the nature of the service provided by GTPL.
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