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...
Tribunal held that cost of facilities provided by service recipient to Central Industrial Security Force for rendering security services, such as barrack accommodation, medical expenses, lease accommodation, telephone charges, vehicle hiring, stationery, miscellaneous expenses, is not includible in gross value for service tax u/s 67 of Finance Act, 1994. Relying on Supreme Court's decision in Bhayana Builders, Tribunal ruled that free supplies do not form part of total value for service tax. Consequently, demand of service tax on such facilities was set aside.
Tribunal held that cost of facilities provided by service recipient to Central Industrial Security Force for rendering security services, such as barrack accommodation, medical expenses, lease accommodation, telephone charges, vehicle hiring, stationery, miscellaneous expenses, is not includible in gross value for service tax u/s 67 of Finance Act, 1994. Relying on Supreme Court's decision in Bhayana Builders, Tribunal ruled that free supplies do not form part of total value for service tax. Consequently, demand of service tax on such facilities was set aside.
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