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...
The CESTAT dismissed the Revenue's appeal, ruling that port services qualify as 'place of removal' for availing CENVAT credit on cargo handling services used for exporting goods. The Gujarat High Court had previously held that cargo handling services availed for exporting goods are essentially rendered at the port from where goods are taken out of the country. Furthermore, the issue was one of interpretation rather than suppression, so the extended period for issuing the show cause notice demanding reversal of CENVAT credit was not justified due to time limitation.
The CESTAT dismissed the Revenue's appeal, ruling that port services qualify as 'place of removal' for availing CENVAT credit on cargo handling services used for exporting goods. The Gujarat High Court had previously held that cargo handling services availed for exporting goods are essentially rendered at the port from where goods are taken out of the country. Furthermore, the issue was one of interpretation rather than suppression, so the extended period for issuing the show cause notice demanding reversal of CENVAT credit was not justified due to time limitation.
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