Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
Cenvat Credit case involving invoices issued by Merchant Exporter for services related to fulfilling Minimum Indicative Export Quota and invoices from U.P. Sugar Mills Cogen Association for contribution to install Gateway System. Appellant denied credit on contribution for Gateway System as per Supreme Court ruling disallowing credit on electricity cleared at contractual rates. Credit on Merchant Exporter's invoices disallowed as services unrelated to manufacturing activities, definition of input service amended restrictively in 2011. Extended period invoked correctly as appellant suppressed facts by not disclosing tripartite agreement and availing credit on unrelated services. Penalty under Cenvat Credit Rules upheld for demand related to Merchant Exporter's invoices. Interest demand upheld as credit wrongly availed. Appeal partially allowed.
Cenvat Credit case involving invoices issued by Merchant Exporter for services related to fulfilling Minimum Indicative Export Quota and invoices from U.P. Sugar Mills Cogen Association for contribution to install Gateway System. Appellant denied credit on contribution for Gateway System as per Supreme Court ruling disallowing credit on electricity cleared at contractual rates. Credit on Merchant Exporter's invoices disallowed as services unrelated to manufacturing activities, definition of input service amended restrictively in 2011. Extended period invoked correctly as appellant suppressed facts by not disclosing tripartite agreement and availing credit on unrelated services. Penalty under Cenvat Credit Rules upheld for demand related to Merchant Exporter's invoices. Interest demand upheld as credit wrongly availed. Appeal partially allowed.
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