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...
Refund of accumulated CENVAT credit on exported services is not barred merely because credit from an earlier period is claimed in a subsequent quarter. Notification No. 5/2006-CE (NT) and the Board clarification permit carry-forward, subject to limitation and other claim requirements. For reverse-charge service tax paid belatedly, limitation runs from the actual tax-payment date; a period stated incorrectly in the application may be treated as a clerical error where returns establish the payment date. Both Members agreed that the refund rejection could not stand on those grounds. They differed on whether issues beyond the show cause notice required remand or whether refund with interest should be granted, and referred that question to a Third Member.
Refund of accumulated CENVAT credit on exported services is not barred merely because credit from an earlier period is claimed in a subsequent quarter. Notification No. 5/2006-CE (NT) and the Board clarification permit carry-forward, subject to limitation and other claim requirements. For reverse-charge service tax paid belatedly, limitation runs from the actual tax-payment date; a period stated incorrectly in the application may be treated as a clerical error where returns establish the payment date. Both Members agreed that the refund rejection could not stand on those grounds. They differed on whether issues beyond the show cause notice required remand or whether refund with interest should be granted, and referred that question to a Third Member.
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