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...
CENVAT Credit - Works Contract Services - Input Services - The expression “modernisation, renovation or repairs of a factory” was appearing in the definition of ‘input service’ both before and after 01.07.2012. It has not been denied by the department that the Coke Oven Project of the appellants was towards modernization and renovation of their existing plant/factory. - Appellants have correctly taken credit of service tax paid/borne in respect of all services - AT
CENVAT Credit - Works Contract Services - Input Services - The expression “modernisation, renovation or repairs of a factory” was appearing in the definition of ‘input service’ both before and after 01.07.2012. It has not been denied by the department that the Coke Oven Project of the appellants was towards modernization and renovation of their existing plant/factory. - Appellants have correctly taken credit of service tax paid/borne in respect of all services - AT
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