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 adjudicated a service tax dispute involving vessel chartering services. The tribunal determined that fuel, bunker, and water charges incurred prior to vessel delivery cannot be included in the taxable service value. The appellants' reimbursement for these pre-delivery goods, which were subject to VAT, were deemed separate from the core charter service. The tribunal distinguished between goods supply and service provision, specifically noting that the fuel and water supplied during vessel delivery preparation do not constitute part of the taxable service contract. Consequently, these charges cannot be incorporated into the assessable value for service tax calculation. The appeal was allowed, excluding these preliminary supply costs from tax computation.
CESTAT adjudicated a service tax dispute involving vessel chartering services. The tribunal determined that fuel, bunker, and water charges incurred prior to vessel delivery cannot be included in the taxable service value. The appellants' reimbursement for these pre-delivery goods, which were subject to VAT, were deemed separate from the core charter service. The tribunal distinguished between goods supply and service provision, specifically noting that the fuel and water supplied during vessel delivery preparation do not constitute part of the taxable service contract. Consequently, these charges cannot be incorporated into the assessable value for service tax calculation. The appeal was allowed, excluding these preliminary supply costs from tax computation.
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