Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
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 on immovable property constructed after issuance of completion certificate is not permissible, as transaction is treated as sale of goods, not service. Cenvat credit can be taken only on receipt of inputs and within one year from date of documents. Extended period of limitation rightly invoked as appellant was aware of ineligibility for credit after completion certificate. Imposition of penalty u/s 78 and levy of interest upheld. Appeal dismissed by Appellate Tribunal.
Cenvat credit on immovable property constructed after issuance of completion certificate is not permissible, as transaction is treated as sale of goods, not service. Cenvat credit can be taken only on receipt of inputs and within one year from date of documents. Extended period of limitation rightly invoked as appellant was aware of ineligibility for credit after completion certificate. Imposition of penalty u/s 78 and levy of interest upheld. Appeal dismissed by Appellate Tribunal.
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