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...
According to the SCN and impugned order themselves there was no manufacture of the subject goods, there can be no levy and hence no requirement to make payment of any duty of central excise payable in respect of subject machineries under the Act. Consequently, the question of any recovery of “duties of excise” not levied or not paid or short levied or short paid or erroneously refunded in terms of Section 11A(1) of the Act also does not arise.
According to the SCN and impugned order themselves there was no manufacture of the subject goods, there can be no levy and hence no requirement to make payment of any duty of central excise payable in respect of subject machineries under the Act. Consequently, the question of any recovery of “duties of excise” not levied or not paid or short levied or short paid or erroneously refunded in terms of Section 11A(1) of the Act also does not arise.
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