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...
Benefit of exemption from service tax - Vehicle Hire Charges - Rent received for their trailers (vehicles) - Supply of transport vehicles to Goods Transport Agency - Despite the appellant’s contention that these services were exempt under various notifications, the tribunal agreed with the Commissioner that the exemption notifications needed strict interpretation, and it was the appellant's burden to prove their eligibility for exemption, which they failed to do by not meeting specific conditions outlined in the notifications.
Benefit of exemption from service tax - Vehicle Hire Charges - Rent received for their trailers (vehicles) - Supply of transport vehicles to Goods Transport Agency - Despite the appellant’s contention that these services were exempt under various notifications, the tribunal agreed with the Commissioner that the exemption notifications needed strict interpretation, and it was the appellant's burden to prove their eligibility for exemption, which they failed to do by not meeting specific conditions outlined in the notifications.
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