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...
Refund claim of the amount of pre- deposit - As per the cenvat credit rules, an assessee can take the cenvat credit of any duty paid on the inputs used in the manufacture of final product cleared on payment of duty - In the present case the amount of redemption fine is not eligible as cenvat credit as the same is not a duty which was paid on any input received by the appellant. The right course of action about refund of the amount of bank guarantee adjusted against the redemption fine is to file a formal refund claim. - AT
Refund claim of the amount of pre- deposit - As per the cenvat credit rules, an assessee can take the cenvat credit of any duty paid on the inputs used in the manufacture of final product cleared on payment of duty - In the present case the amount of redemption fine is not eligible as cenvat credit as the same is not a duty which was paid on any input received by the appellant. The right course of action about refund of the amount of bank guarantee adjusted against the redemption fine is to file a formal refund claim. - AT
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