Revenue neutrality in domestic related-party loans can require deletion of interest transfer pricing adjustments after domestic-transaction verificati...
The judgments dealing with the specific issue will prevail over the judgment in respect of general principle of the Cenvat Credit Rules - there are no mala fide on the part of the respondent. Therefore the Adjudicating Authority’s order setting aside the demand of Cenvat credit on Sales Commission exclusively on the ground of time bar is not found any fault. Therefore, the extended period was not invokable for the demand beyond the normal period. - AT
The judgments dealing with the specific issue will prevail over the judgment in respect of general principle of the Cenvat Credit Rules - there are no mala fide on the part of the respondent. Therefore the Adjudicating Authority’s order setting aside the demand of Cenvat credit on Sales Commission exclusively on the ground of time bar is not found any fault. Therefore, the extended period was not invokable for the demand beyond the normal period. - AT
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