Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Area Based Exemption - The appellant, engaged in the manufacture of pharmaceutical products in Sikkim, applied for a special rate of value addition at 73.5% for FY 2009-10 to claim a refund of central excise duty. The application was rejected by the authorities, citing a value addition of 58.86%. The appellant contested this, arguing that the actual cost of raw materials should be considered, not a notional value. The appeal was allowed by the tribunal, and the impugned order was set aside, granting the appellant relief.
Area Based Exemption - The appellant, engaged in the manufacture of pharmaceutical products in Sikkim, applied for a special rate of value addition at 73.5% for FY 2009-10 to claim a refund of central excise duty. The application was rejected by the authorities, citing a value addition of 58.86%. The appellant contested this, arguing that the actual cost of raw materials should be considered, not a notional value. The appeal was allowed by the tribunal, and the impugned order was set aside, granting the appellant relief.
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