Supervisory permanent establishment requires project-wise duration and qualifying construction nexus; offshore supplies and salary reimbursements rema...
Transfer-pricing comparability permits fresh objections and filters where software service comparables are functionally unsuitable for arm's-length pr...
Territorial rendering requirement excludes China-based management and consultancy services from fees for technical services under the India-China DTAA...
Revenue Neutrality - CENVAT Credit - rejected goods - rectify/re-make the goods for sale - the appellant has cleared these goods to their another unit. Admittedly, whatever duty have been paid, the same are entitled to cenvat credit to themselves. In that circumstances, it is a revenue neutral situation. In that circumstances also, the appellant are not required to pay any differential duty or any amount on account of cenvat credit. - AT
Revenue Neutrality - CENVAT Credit - rejected goods - rectify/re-make the goods for sale - the appellant has cleared these goods to their another unit. Admittedly, whatever duty have been paid, the same are entitled to cenvat credit to themselves. In that circumstances, it is a revenue neutral situation. In that circumstances also, the appellant are not required to pay any differential duty or any amount on account of cenvat credit. - AT
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