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...
CENVAT Credit - Capital goods - Inputs - Cement and Steel items - There is no blanket or absolute bar in claiming credit on the disputed items, unless used for the purposes specifically excluded in Explanation 2 to the definition of inputs. The Appellant had placed a Certificate from the Chartered Engineer, in support of their contention that the disputed items were used in the fabrication of the storage tanks within the factory premises. - Credit allowed as inputs - AT
CENVAT Credit - Capital goods - Inputs - Cement and Steel items - There is no blanket or absolute bar in claiming credit on the disputed items, unless used for the purposes specifically excluded in Explanation 2 to the definition of inputs. The Appellant had placed a Certificate from the Chartered Engineer, in support of their contention that the disputed items were used in the fabrication of the storage tanks within the factory premises. - Credit allowed as inputs - AT
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