Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Marketing and administrative support services rendered to an overseas entity were treated as export of services because the recipient was outside India, payment was received in convertible foreign exchange, and the arrangement was on a principal-to-principal basis; the place where work was performed in India was not determinative, so the service tax demand, interest and penalty were set aside. CENVAT credit denial for want of supporting documents also failed because the credit was disclosed in ST-3 returns and supporting invoices were produced during audit and refund proceedings, so the denial with interest and penalty was set aside. The extended period was unavailable in the absence of suppression, and the penalty for delayed registration survived only to the statutory ceiling.
Marketing and administrative support services rendered to an overseas entity were treated as export of services because the recipient was outside India, payment was received in convertible foreign exchange, and the arrangement was on a principal-to-principal basis; the place where work was performed in India was not determinative, so the service tax demand, interest and penalty were set aside. CENVAT credit denial for want of supporting documents also failed because the credit was disclosed in ST-3 returns and supporting invoices were produced during audit and refund proceedings, so the denial with interest and penalty was set aside. The extended period was unavailable in the absence of suppression, and the penalty for delayed registration survived only to the statutory ceiling.
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