Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
Bank account freezing requires statutory authority; anti-money-laundering compliance and KYC monitoring do not permit unilateral indefinite restrictio...
Levy of interest and penalty - In the instant case, in view of the discussions, with the consent and concurrence of both the parties, instead of remanding it back, Rule 41 of the CESTAT (Procedure) Rule, 1982 should be invoked in, putting an end to the litigation that commenced way back in the early 1990’s only for the purpose of re-computation for the normal period when from the evidence on record it is quite evident that appellant had already paid Rs.3,50,000/- during investigation which is much higher than the entire demand raised for the normal period that would also meet the interest component. - AT
Levy of interest and penalty - In the instant case, in view of the discussions, with the consent and concurrence of both the parties, instead of remanding it back, Rule 41 of the CESTAT (Procedure) Rule, 1982 should be invoked in, putting an end to the litigation that commenced way back in the early 1990’s only for the purpose of re-computation for the normal period when from the evidence on record it is quite evident that appellant had already paid Rs.3,50,000/- during investigation which is much higher than the entire demand raised for the normal period that would also meet the interest component. - AT
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