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 services - erection and commissioning of machines carried out in China and Italy based on invoices / debit notes raised by M/s.Voltas Ltd., Coimbatore - The department contested the eligibility, arguing that these services were not directly related to the manufacture of the appellant's finished products. However, the Appellate Tribunal ruled in favor of the appellant, citing the broad definition of "input services" during the relevant period, which encompassed activities relating to business. Additionally, they acknowledged the necessity of the outsourced services for the operation of the exported machines, thereby allowing the appellant's claim for credit.
CENVAT Credit - input services - erection and commissioning of machines carried out in China and Italy based on invoices / debit notes raised by M/s.Voltas Ltd., Coimbatore - The department contested the eligibility, arguing that these services were not directly related to the manufacture of the appellant's finished products. However, the Appellate Tribunal ruled in favor of the appellant, citing the broad definition of "input services" during the relevant period, which encompassed activities relating to business. Additionally, they acknowledged the necessity of the outsourced services for the operation of the exported machines, thereby allowing the appellant's claim for credit.
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