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 - input service - non-payment of service tax on Ocean Freight - non-payment of service tax on Government Fees under RCM - The Appellate Tribunal considered various issues related to the eligibility of CENVAT credit and payment of service tax. It found in favor of the appellant on several counts, allowing credit on input services, RCM liability, education cess, goods used for maintenance, and ruling against the levy of service tax on ocean freight and government fees under RCM. However, excess credit allocation to one unit was disallowed, as it violated Rule 7 of the CENVAT Credit Rules.
CENVAT Credit - input service - non-payment of service tax on Ocean Freight - non-payment of service tax on Government Fees under RCM - The Appellate Tribunal considered various issues related to the eligibility of CENVAT credit and payment of service tax. It found in favor of the appellant on several counts, allowing credit on input services, RCM liability, education cess, goods used for maintenance, and ruling against the levy of service tax on ocean freight and government fees under RCM. However, excess credit allocation to one unit was disallowed, as it violated Rule 7 of the CENVAT Credit Rules.
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