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...
CESTAT New Delhi held that providing Corporate Guarantee without consideration is not taxable u/s 66B of Finance Act, 1994 as it lacks 'provider' and 'consideration' elements. Profit/markup is taxable under service tax based on precedent cases like M/s Tiger Logistics (India) Ltd. The tribunal upheld the order, dismissing the revenue appeal.
CESTAT New Delhi held that providing Corporate Guarantee without consideration is not taxable u/s 66B of Finance Act, 1994 as it lacks 'provider' and 'consideration' elements. Profit/markup is taxable under service tax based on precedent cases like M/s Tiger Logistics (India) Ltd. The tribunal upheld the order, dismissing the revenue appeal.
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