Revenue-neutral domestic transfer pricing and mirror transactions justified deletion of related-party adjustments for operation, maintenance and port ...
Penalty u/s 78 - reverse charge mechanism - revenue neutrality - assessee could have gained nothing since the entire amount could have been available to them as CENVAT credit. Since the entire exercise is revenue neutral, no mala fide can be attributed to them - No penalty.
Penalty u/s 78 - reverse charge mechanism - revenue neutrality - assessee could have gained nothing since the entire amount could have been available to them as CENVAT credit. Since the entire exercise is revenue neutral, no mala fide can be attributed to them - No penalty.
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