Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
CENVAT credit was denied on ISD invoices for not containing prescribed particulars u/r 4A of Service Tax Rules, 1994. The appellant had availed credit by splitting service tax, education cess, and secondary higher education cess, which was held permissible as per Notification No. 10/2007-CE (NT). Regarding availment of credit on ISD invoices without receiving input services, it was held following Karnataka High Court's decision that the assessee is entitled to distribute CENVAT credit on input services to manufacturing or other units providing output services. The appellant was eligible for availing the credit, and the demand and penalty were set aside. The appeal was allowed.
CENVAT credit was denied on ISD invoices for not containing prescribed particulars u/r 4A of Service Tax Rules, 1994. The appellant had availed credit by splitting service tax, education cess, and secondary higher education cess, which was held permissible as per Notification No. 10/2007-CE (NT). Regarding availment of credit on ISD invoices without receiving input services, it was held following Karnataka High Court's decision that the assessee is entitled to distribute CENVAT credit on input services to manufacturing or other units providing output services. The appellant was eligible for availing the credit, and the demand and penalty were set aside. The appeal was allowed.
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