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...
Validity of SCN - Whether the corrigendum/addendum to the show-cause notice is valid in law? - The addendum supplements the allegations in the original show-cause notice and states that out of the original demand of inadmissible credit, remaining amount is also inadmissible on the allegation that the CENVAT credit was fraudulently availed on bogus invoices issued by non-existing/fraudulent suppliers. Therefore, there is no legal infirmity in the issuance of addendum in this regard. - AT
Validity of SCN - Whether the corrigendum/addendum to the show-cause notice is valid in law? - The addendum supplements the allegations in the original show-cause notice and states that out of the original demand of inadmissible credit, remaining amount is also inadmissible on the allegation that the CENVAT credit was fraudulently availed on bogus invoices issued by non-existing/fraudulent suppliers. Therefore, there is no legal infirmity in the issuance of addendum in this regard. - AT
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