Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
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Refund claim - amount paid on reversal of credit alongwith interest and penalty - no intimation of appellant accepting their liability - if at all the Revenue is of the view that the amount is legally payable, it was incumbent on the Revenue to issue a SCN which they failed to do so - appellant is entitled for refund of the amount of Cenvat Credit, interest and penalty paid by them
Refund claim - amount paid on reversal of credit alongwith interest and penalty - no intimation of appellant accepting their liability - if at all the Revenue is of the view that the amount is legally payable, it was incumbent on the Revenue to issue a SCN which they failed to do so - appellant is entitled for refund of the amount of Cenvat Credit, interest and penalty paid by them
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