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...
Validity of demand of service tax - The case involved appeals against an order regarding service tax demands and penalties. The Appellate Tribunal addressed multiple issues raised by the parties. Firstly, it ruled that a demand already paid prior to the show cause notice should not have been included, as it fell under section 73(3) and was not excluded by section 73(4). Secondly, it set aside the demand and penalty for non-payment of service tax reflected in ST-3 returns, as the extended period of limitation was not properly invoked. Additionally, it upheld the Commissioner's finding regarding the reversal of a demand under rule 6(3) of the Credit Rules.
Validity of demand of service tax - The case involved appeals against an order regarding service tax demands and penalties. The Appellate Tribunal addressed multiple issues raised by the parties. Firstly, it ruled that a demand already paid prior to the show cause notice should not have been included, as it fell under section 73(3) and was not excluded by section 73(4). Secondly, it set aside the demand and penalty for non-payment of service tax reflected in ST-3 returns, as the extended period of limitation was not properly invoked. Additionally, it upheld the Commissioner's finding regarding the reversal of a demand under rule 6(3) of the Credit Rules.
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