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...
Reversal of Cenvat Credit - The Tribunal interprets Rule 6(3A)(c)(iii) to mean that "total Cenvat credit" should only include common input and input services, not those exclusively used for dutiable goods. They find in favor of the appellant on this issue. - Regarding the prospective applicability of Notification No. 13/2016-CE (NT), the CESTAT determines that the amendment to Rule 6(3A) should have retrospective effect, supporting the appellant's argument. - The Tribunal also agrees with the appellant on the treatment of LPG & SKO as by-products, finding no reversal required for these items.
Reversal of Cenvat Credit - The Tribunal interprets Rule 6(3A)(c)(iii) to mean that "total Cenvat credit" should only include common input and input services, not those exclusively used for dutiable goods. They find in favor of the appellant on this issue. - Regarding the prospective applicability of Notification No. 13/2016-CE (NT), the CESTAT determines that the amendment to Rule 6(3A) should have retrospective effect, supporting the appellant's argument. - The Tribunal also agrees with the appellant on the treatment of LPG & SKO as by-products, finding no reversal required for these items.
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