Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
Undisclosed foreign asset classification requires an unexplained source; unrebutted affidavits and corroborative evidence defeated the Black Money Act...
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
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
