Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
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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