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...
Denial of CENVAT credit of tax - From a plain reading of the germane definitions in CENVAT Credit Rules, 2004, we also find that the distinction drawn between ‘input’ and ‘input service’ for deploying the expression ‘whether directly or indirectly’ also appears to have been overlooked by central excise authorities - The lack of finding in the impugned order on the applicability of the main leg of the definition and its nexus with the final output hinders the exercise of appellate determination. - AT
Denial of CENVAT credit of tax - From a plain reading of the germane definitions in CENVAT Credit Rules, 2004, we also find that the distinction drawn between ‘input’ and ‘input service’ for deploying the expression ‘whether directly or indirectly’ also appears to have been overlooked by central excise authorities - The lack of finding in the impugned order on the applicability of the main leg of the definition and its nexus with the final output hinders the exercise of appellate determination. - AT
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