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 - Auction of abandoned imported goods by the CONCOR - ground rent/storage rendered towards the un-cleared/un-claimed cargo of the importer - The Tribunal emphasized that in the auction transaction of abandoned goods, no service recipient exists, thus no service is provided. They cited Sections 48 and 150 of the Customs Act, 1962, which deal with the sale of goods not cleared, and stressed that these sections make no provision for any service rendered. The Tribunal analyzed the relevant provisions of the Finance Act, 1994, which stipulate that to attract service tax, there must be a taxable service provided to a service recipient in exchange for consideration.
Levy of service tax - Auction of abandoned imported goods by the CONCOR - ground rent/storage rendered towards the un-cleared/un-claimed cargo of the importer - The Tribunal emphasized that in the auction transaction of abandoned goods, no service recipient exists, thus no service is provided. They cited Sections 48 and 150 of the Customs Act, 1962, which deal with the sale of goods not cleared, and stressed that these sections make no provision for any service rendered. The Tribunal analyzed the relevant provisions of the Finance Act, 1994, which stipulate that to attract service tax, there must be a taxable service provided to a service recipient in exchange for consideration.
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