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...
Refund of CENVAT Credit - The appellants have claimed the refund in respect of the input service used in relation to export of finished goods, therefore, the refund is correctly governed by Rule 5 read with Notification No. 27 of 2012-CE(NT), therefore, rejection of refund referring to Notification 41/2007-ST is absolutely incorrect being not relevant. - even if the document is bearing the name and address of the Mumbai office, only on this ground, refund cannot be rejected since service is attributed to the appellant’s factory. - AT
Refund of CENVAT Credit - The appellants have claimed the refund in respect of the input service used in relation to export of finished goods, therefore, the refund is correctly governed by Rule 5 read with Notification No. 27 of 2012-CE(NT), therefore, rejection of refund referring to Notification 41/2007-ST is absolutely incorrect being not relevant. - even if the document is bearing the name and address of the Mumbai office, only on this ground, refund cannot be rejected since service is attributed to the appellant’s factory. - AT
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