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...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
CENVAT credit on MS scrap received under registered dealer invoices was admissible where valid invoices, banking payments, statutory records, transport-service tax and evidence of consumption supported receipt, while manufacture and clearance of finished goods remained undisputed. The Revenue had to prove non-receipt through affirmative evidence and identify an alternative raw-material source; suspicion and incomplete investigation were insufficient. Uncorroborated, contradictory investigation statements could not sustain denial without compliance with Section 9D safeguards. Limited Vahan portal vehicle discrepancies, without examination of vehicle owners or independent evidence, could not establish fictitious transactions. Extended limitation was unavailable because statutory returns and records disclosed the credit and no fraud, collusion, wilful misstatement or suppression with intent to evade duty was proved. Credit reversal, interest and penalties were set aside.
CENVAT credit on MS scrap received under registered dealer invoices was admissible where valid invoices, banking payments, statutory records, transport-service tax and evidence of consumption supported receipt, while manufacture and clearance of finished goods remained undisputed. The Revenue had to prove non-receipt through affirmative evidence and identify an alternative raw-material source; suspicion and incomplete investigation were insufficient. Uncorroborated, contradictory investigation statements could not sustain denial without compliance with Section 9D safeguards. Limited Vahan portal vehicle discrepancies, without examination of vehicle owners or independent evidence, could not establish fictitious transactions. Extended limitation was unavailable because statutory returns and records disclosed the credit and no fraud, collusion, wilful misstatement or suppression with intent to evade duty was proved. Credit reversal, interest and penalties were set aside.
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