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Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
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Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Refund of unutilized CENVAT credit accumulated - Once it is established that the Appellants are providing output service they are entitled to take credit of input service. It is an admitted fact that credit proportionate to services provided within the taxable territory has been reversed. After such reversal remaining unutilized CENVAT Credit pertains only to export of legal services and becomes eligible for refund in terms of Rule 5 of CCR and Notification no. 27/2012-CE(NT) - AT
Refund of unutilized CENVAT credit accumulated - Once it is established that the Appellants are providing output service they are entitled to take credit of input service. It is an admitted fact that credit proportionate to services provided within the taxable territory has been reversed. After such reversal remaining unutilized CENVAT Credit pertains only to export of legal services and becomes eligible for refund in terms of Rule 5 of CCR and Notification no. 27/2012-CE(NT) - AT
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