Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
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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