Patent-settlement expenditure treated as commercially expedient revenue outlay, with foreign-law restrictions inapplicable before the prospective amen...
International transaction benchmarking restricts transfer pricing adjustments to associated-enterprise dealings, while functional comparability govern...
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Denial of benefit of Notification No. 12/03-ST - it can be seen that as against the abatement of 67% available under Notification No. 15/04-ST and 01/06-ST - the appellant have taken the abatement ranging from 30% to 48%. Thus, despite the availability of abatement as per the above notification, the appellant have paid the service tax on much higher value, for this reason also the demand is absolutely unsustainable. - AT
Denial of benefit of Notification No. 12/03-ST - it can be seen that as against the abatement of 67% available under Notification No. 15/04-ST and 01/06-ST - the appellant have taken the abatement ranging from 30% to 48%. Thus, despite the availability of abatement as per the above notification, the appellant have paid the service tax on much higher value, for this reason also the demand is absolutely unsustainable. - AT
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