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 - exempt service or not - amount of interest received by the appellant on the delayed payment of the amount of consideration received from the sale of flats/villas/shops - The Tribunal observed that the interest received is akin to liquidated damages or compensation and does not constitute an exempted service. Therefore, the appellant is not liable for reversal of Cenvat credit based on this interest. The appellant did not perform any service to receive the interest; it was merely a deterrent for delayed payments, thus not requiring reversal of Cenvat credit.
CENVAT Credit - exempt service or not - amount of interest received by the appellant on the delayed payment of the amount of consideration received from the sale of flats/villas/shops - The Tribunal observed that the interest received is akin to liquidated damages or compensation and does not constitute an exempted service. Therefore, the appellant is not liable for reversal of Cenvat credit based on this interest. The appellant did not perform any service to receive the interest; it was merely a deterrent for delayed payments, thus not requiring reversal of Cenvat credit.
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