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...
Refund of CENVAT Credit - services related to Information Technology (ITSS) - The appellate tribunal analyzed submissions regarding the eligibility for refund on ITSS, the denial of CENVAT credit, denial of credit for service tax paid on generators, and discrepancies between CENVAT records and ST-3 returns. The Tribunal found that while the appellant demonstrated independence from M/s Agilent Technologies (Singapore), they failed to provide evidence of valid orders for ITSS services, leading to the denial of the refund claim. However, they ruled in favor of the appellant regarding the denial of CENVAT credit, credit for service tax paid on generators, and discrepancies between records, remanding these matters for further verification and consideration by the Original Authority.
Refund of CENVAT Credit - services related to Information Technology (ITSS) - The appellate tribunal analyzed submissions regarding the eligibility for refund on ITSS, the denial of CENVAT credit, denial of credit for service tax paid on generators, and discrepancies between CENVAT records and ST-3 returns. The Tribunal found that while the appellant demonstrated independence from M/s Agilent Technologies (Singapore), they failed to provide evidence of valid orders for ITSS services, leading to the denial of the refund claim. However, they ruled in favor of the appellant regarding the denial of CENVAT credit, credit for service tax paid on generators, and discrepancies between records, remanding these matters for further verification and consideration by the Original Authority.
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