Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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...
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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