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...
The case involved a dispute u/s CESTAT regarding the rejection of a refund claim based on the classification of services. The Appellant argued that the service provided was not "renting of immovable property" but "construction services." However, the Tribunal held that the Appellant cannot challenge the classification chosen by the service provider, who treated it as "renting of immovable property" and paid Service Tax accordingly. The Appellant failed to provide evidence to support their claim, leading to the rejection of the refund. The appeal was dismissed, and the request for remand was denied.
The case involved a dispute u/s CESTAT regarding the rejection of a refund claim based on the classification of services. The Appellant argued that the service provided was not "renting of immovable property" but "construction services." However, the Tribunal held that the Appellant cannot challenge the classification chosen by the service provider, who treated it as "renting of immovable property" and paid Service Tax accordingly. The Appellant failed to provide evidence to support their claim, leading to the rejection of the refund. The appeal was dismissed, and the request for remand was denied.
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