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 violations of natural justice, service tax Composition Scheme, and valuation issues. The tribunal held that free materials supplied by recipients should not be included in taxable value without investigation. Demand based solely on Form 26AS and returns was deemed impermissible. The extended limitation period was inapplicable as the appellant had a tax record. Pre-amendment Section 73 barred penalty due to non-invoke of extended period. The order was set aside and the appeal allowed.
The case involved violations of natural justice, service tax Composition Scheme, and valuation issues. The tribunal held that free materials supplied by recipients should not be included in taxable value without investigation. Demand based solely on Form 26AS and returns was deemed impermissible. The extended limitation period was inapplicable as the appellant had a tax record. Pre-amendment Section 73 barred penalty due to non-invoke of extended period. The order was set aside and the appeal allowed.
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