Transfer pricing comparability under TNMM: foreign exchange loss on ECB excluded from operating cost, and a functionally dissimilar comparator removed...
Fake AI-generated precedents vitiate adjudication, with unverified citations contaminating the decision-making process and undermining the rule of law...
Refund of CENVAT Credit - export of goods - The condition 5 of the aforesaid Notification No. 11/2002-CE (NT) does not mean that the appellant should not be able to utilize the credit at all. It is to be read harmoniously to mean that the refund should be allowed for the manufacturer if the assessee is not in a position to utilize the Cenvat credit within a reasonable period.
Refund of CENVAT Credit - export of goods - The condition 5 of the aforesaid Notification No. 11/2002-CE (NT) does not mean that the appellant should not be able to utilize the credit at all. It is to be read harmoniously to mean that the refund should be allowed for the manufacturer if the assessee is not in a position to utilize the Cenvat credit within a reasonable period.
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