Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Period of limitation - Relevant date - There is no dispute that the relevant date in the present case is 25.11.2012. Prior to this date on 28.05.2012, section 73(1) of the Finance Act was amended and it was provided that the Central Excise Officer could issue a notice within eighteen months from the relevant date. The show cause notice was issued on 08.05.2014, which would be within eighteen months from 25.11.2012 - Commissioner (Appeals), therefore, committed no illegality in holding that the demand for the period 01.04.2012 to 30.06.2012 was within the statutory period of eighteen months from the relevant date. - AT
Period of limitation - Relevant date - There is no dispute that the relevant date in the present case is 25.11.2012. Prior to this date on 28.05.2012, section 73(1) of the Finance Act was amended and it was provided that the Central Excise Officer could issue a notice within eighteen months from the relevant date. The show cause notice was issued on 08.05.2014, which would be within eighteen months from 25.11.2012 - Commissioner (Appeals), therefore, committed no illegality in holding that the demand for the period 01.04.2012 to 30.06.2012 was within the statutory period of eighteen months from the relevant date. - AT
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