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...
Service tax liability on construction of residential complexes assessed on accrual basis as per Point of Taxation Rules, 2011, overriding receipt basis followed earlier. Appellant directed to reconcile tax paid on receipt basis with accrual basis liability, pay interest on delay. Service tax upheld on Preferential Location Charges based on Bombay High Court ruling that separate charge for service attracts tax, not a tax on land. Appeal dismissed by CESTAT, finding no merits.
Service tax liability on construction of residential complexes assessed on accrual basis as per Point of Taxation Rules, 2011, overriding receipt basis followed earlier. Appellant directed to reconcile tax paid on receipt basis with accrual basis liability, pay interest on delay. Service tax upheld on Preferential Location Charges based on Bombay High Court ruling that separate charge for service attracts tax, not a tax on land. Appeal dismissed by CESTAT, finding no merits.
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