Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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CENVAT credit on input services received at premises omitted from a centralised registration cannot be denied solely because those premises are unregistered. In contrast, works contract services used to construct or set up BPO branches fall within the exclusion for construction of buildings or civil structures, making related credit inadmissible. Where disputed credit was disclosed in ST-3 returns and refund claims, audit detection alone does not establish suppression or other conditions for extended limitation; recovery is confined to the normal period and requires recomputation. Interest follows on recoverable inadmissible credit, but penalties based on suppression or failure to include premises are unsustainable without the requisite contravention or intent to evade.
CENVAT credit on input services received at premises omitted from a centralised registration cannot be denied solely because those premises are unregistered. In contrast, works contract services used to construct or set up BPO branches fall within the exclusion for construction of buildings or civil structures, making related credit inadmissible. Where disputed credit was disclosed in ST-3 returns and refund claims, audit detection alone does not establish suppression or other conditions for extended limitation; recovery is confined to the normal period and requires recomputation. Interest follows on recoverable inadmissible credit, but penalties based on suppression or failure to include premises are unsustainable without the requisite contravention or intent to evade.
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