Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Clandestine removal - finished goods found short during the stock taking - since these were captively consumed they were exempt from duty under notification 67/95-CE dated 16.03.1995. The Commissioner’s finding that the exemption does not apply to ‘finished goods’ is legally not sustainable because of the specific definition of ‘inputs’ in the said notification which covers virtually all excisable goods including the goods manufactured by the appellants. - AT
Clandestine removal - finished goods found short during the stock taking - since these were captively consumed they were exempt from duty under notification 67/95-CE dated 16.03.1995. The Commissioner’s finding that the exemption does not apply to ‘finished goods’ is legally not sustainable because of the specific definition of ‘inputs’ in the said notification which covers virtually all excisable goods including the goods manufactured by the appellants. - AT
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