Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Invocation of Extended period of Limitation - Even if there was any additional duty payable by the appellant, the same would be admissible as CENVAT credit to its own Raigarh unit. Such CENVAT credit would have been utilized by the Raigarh unit for payment of central excise duty at its end. Therefore, the entire exercise of demanding any further excise duty would be revenue neutral. - Demand set aside - AT
Invocation of Extended period of Limitation - Even if there was any additional duty payable by the appellant, the same would be admissible as CENVAT credit to its own Raigarh unit. Such CENVAT credit would have been utilized by the Raigarh unit for payment of central excise duty at its end. Therefore, the entire exercise of demanding any further excise duty would be revenue neutral. - Demand set aside - AT
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