Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
Refund of CENVAT Credit - time limitation - Rule 5 of CENVAT Credit Rules itself clearly specifying that such refund claims would be subject to “such safeguards, conditions and limitations as may be specified, by the Central Government, by notification” and the above referred notification No.5/2006 and 27/2012 clearly specifying in clause (6) and clause 3.0(b) respectively that “before the expiry of the period specified in Section 11-B of the Central Excise Act, 1944” it cannot be gainsaid by the appellants that provisions of Section 11-B of the Central Excise Act is not attracted to the refund claims made under CENVAT Credit Rules, 2004.
Refund of CENVAT Credit - time limitation - Rule 5 of CENVAT Credit Rules itself clearly specifying that such refund claims would be subject to “such safeguards, conditions and limitations as may be specified, by the Central Government, by notification” and the above referred notification No.5/2006 and 27/2012 clearly specifying in clause (6) and clause 3.0(b) respectively that “before the expiry of the period specified in Section 11-B of the Central Excise Act, 1944” it cannot be gainsaid by the appellants that provisions of Section 11-B of the Central Excise Act is not attracted to the refund claims made under CENVAT Credit Rules, 2004.
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