Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
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CENVAT Credit - input services - The appellant did not submit the documentary evidences either before the original or first appellate authority to demonstrate that it is entitled to avail the Cenvat credit on some of the disputed services. - Since, the onus lies with the appellant for proper substantiation of the fact regarding availment of Cenvat credit on the disputed services viz., Rent-a-Cab and Travel expenses (Foreign) has not been fulfilled, the denial of Cenvat benefit on such services in the impugned order cannot be faulted. - AT
CENVAT Credit - input services - The appellant did not submit the documentary evidences either before the original or first appellate authority to demonstrate that it is entitled to avail the Cenvat credit on some of the disputed services. - Since, the onus lies with the appellant for proper substantiation of the fact regarding availment of Cenvat credit on the disputed services viz., Rent-a-Cab and Travel expenses (Foreign) has not been fulfilled, the denial of Cenvat benefit on such services in the impugned order cannot be faulted. - AT
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