Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
Joint development agreements defer taxable transfer where possession lacks part performance, while completed flats determine consideration and exempti...
Valuation - Scope of the SCN - Since the entire foundation of the show cause notice is based on the wrong notion that the washery is a “related person” of the appellant, the entire demand is liable to be quashed. Further the invocation of Rule 8 of the Valuation Rules has been done mechanically without even appreciating the fact that there is no captive consumption by the appellant or consumption on its behalf and washing of coal is neither production nor manufacture. - AT
Valuation - Scope of the SCN - Since the entire foundation of the show cause notice is based on the wrong notion that the washery is a “related person” of the appellant, the entire demand is liable to be quashed. Further the invocation of Rule 8 of the Valuation Rules has been done mechanically without even appreciating the fact that there is no captive consumption by the appellant or consumption on its behalf and washing of coal is neither production nor manufacture. - AT
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