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 services - Whether providing space on roof for transportation of parcels/goods can be considered as "Business Support Service" by the Department? - The Tribunal examined the agreement terms and found that the primary activity of the appellant was to provide open space for storage of parcels at bus depots. The Tribunal noted that the appellant charged a license fee for this space, and the responsibility for managing the parcels rested with the company. It was held that this activity did not qualify as "Business Support Service."
Classification of services - Whether providing space on roof for transportation of parcels/goods can be considered as "Business Support Service" by the Department? - The Tribunal examined the agreement terms and found that the primary activity of the appellant was to provide open space for storage of parcels at bus depots. The Tribunal noted that the appellant charged a license fee for this space, and the responsibility for managing the parcels rested with the company. It was held that this activity did not qualify as "Business Support Service."
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