Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
Post-export shipping bill conversion remains available where contemporaneous evidence supports EPCG benefits despite curable procedural omissions and ...
Levy of interest on irregular/excess Cenvat Credit availed but not utilised - The Tribunal acknowledged the inadvertent nature of the appellant's actions and noted that the irregularly availed Cenvat credit had been promptly reversed upon audit notification. - Since the appellant had reversed the credit before the issuance of the show cause notice and no motive to evade tax was established, the extended period was deemed unjustifiable, and the appeal was allowed with consequential relief.
Levy of interest on irregular/excess Cenvat Credit availed but not utilised - The Tribunal acknowledged the inadvertent nature of the appellant's actions and noted that the irregularly availed Cenvat credit had been promptly reversed upon audit notification. - Since the appellant had reversed the credit before the issuance of the show cause notice and no motive to evade tax was established, the extended period was deemed unjustifiable, and the appeal was allowed with consequential relief.
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