Working capital adjustment, comparable selection and trade receivables interest were revisited in transfer pricing, with key additions deleted and rem...
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Invocation of extended period of limitation. - The Appellant had been providing same services as was alleged in the earlier Show Cause Notice dated 22.05.2015 which was adjudicated in favour of the Appellant for the earlier period. It is not the case of the Department that there was any change in the nature of services provided by the Appellant and thus when the first Show Cause Notice was issued invoking extended period of limitation, it cannot be alleged that the Appellant has suppressed facts while issuing demand notices for subsequent period. - Demand set aside - AT
Invocation of extended period of limitation. - The Appellant had been providing same services as was alleged in the earlier Show Cause Notice dated 22.05.2015 which was adjudicated in favour of the Appellant for the earlier period. It is not the case of the Department that there was any change in the nature of services provided by the Appellant and thus when the first Show Cause Notice was issued invoking extended period of limitation, it cannot be alleged that the Appellant has suppressed facts while issuing demand notices for subsequent period. - Demand set aside - AT
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