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...
Demand of interest and penalty - reversal of CENVAT credit prior to issuance of SCN - Rule 14 of the Cenvat Credit Rules the provisions of which were amended to change the words “taken or utilized”, there cannot be any demand for the interest. - As the entire amount of Cenvat credit was reversed prior to issuance of show cause notice, penalty under Section 73(3) of the Finance Act, 1994 is waived off. - AT
Demand of interest and penalty - reversal of CENVAT credit prior to issuance of SCN - Rule 14 of the Cenvat Credit Rules the provisions of which were amended to change the words “taken or utilized”, there cannot be any demand for the interest. - As the entire amount of Cenvat credit was reversed prior to issuance of show cause notice, penalty under Section 73(3) of the Finance Act, 1994 is waived off. - AT
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