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...
CENVAT Credit - common inputs/input services used for manufacture of stock transferred exempted goods (lime stone) and dutiable products (Cement/Clinker) - The Tribunal clarified that the presence of two different final products (limestone as exempted and cement/clinker as dutiable) necessitates the maintenance of separate accounts for inputs/input services used. The court rejected the appellant's interpretation and emphasized that the rules apply to their situation, thus upholding the demand for payment under Rule 6(3)(i) due to the appellant's failure to maintain separate accounts. - However, the CESTAT agreed with the appellant regarding the limitation period, noting no grounds for invoking the extended period due to the appellant's transparent documentation and periodic disclosures.
CENVAT Credit - common inputs/input services used for manufacture of stock transferred exempted goods (lime stone) and dutiable products (Cement/Clinker) - The Tribunal clarified that the presence of two different final products (limestone as exempted and cement/clinker as dutiable) necessitates the maintenance of separate accounts for inputs/input services used. The court rejected the appellant's interpretation and emphasized that the rules apply to their situation, thus upholding the demand for payment under Rule 6(3)(i) due to the appellant's failure to maintain separate accounts. - However, the CESTAT agreed with the appellant regarding the limitation period, noting no grounds for invoking the extended period due to the appellant's transparent documentation and periodic disclosures.
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