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...
Demand of differential service tax - Valuation - non-inclusion on reimbursable expenses - pure agent services - The Appellate Tribunal analyzed the agreements and legal provisions, including previous tribunal decisions and the Service Tax (Determination of Value) Rules, 2006. It concluded that the appellant indeed acted as a pure agent and that reimbursable expenses should not be considered part of taxable services. Consequently, the Tribunal set aside the impugned order, allowing the appeal with consequential relief.
Demand of differential service tax - Valuation - non-inclusion on reimbursable expenses - pure agent services - The Appellate Tribunal analyzed the agreements and legal provisions, including previous tribunal decisions and the Service Tax (Determination of Value) Rules, 2006. It concluded that the appellant indeed acted as a pure agent and that reimbursable expenses should not be considered part of taxable services. Consequently, the Tribunal set aside the impugned order, allowing the appeal with consequential relief.
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