Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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