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...
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CENVAT credit eligibility for various services used by appellant - transportation of household goods of employees, travel/journeys by employees for official purposes, procurement and filling of diesel for DG sets at cell sites, and prefabricated buildings used as shelters treated as capital goods. Tribunal held that during relevant period, definition of 'input services' was wide, covering services used in relation to business. Hence, credit availed on transportation of employee goods, employee travel, diesel procurement/filling eligible as 'input services'. Prefabricated buildings/shelters are accessories to Base Transceiver Station (BTS), qualifying as capital goods eligible for CENVAT credit. Extended period of limitation not invokable as no evidence of suppression with intent to evade tax. Appeal allowed.
CENVAT credit eligibility for various services used by appellant - transportation of household goods of employees, travel/journeys by employees for official purposes, procurement and filling of diesel for DG sets at cell sites, and prefabricated buildings used as shelters treated as capital goods. Tribunal held that during relevant period, definition of 'input services' was wide, covering services used in relation to business. Hence, credit availed on transportation of employee goods, employee travel, diesel procurement/filling eligible as 'input services'. Prefabricated buildings/shelters are accessories to Base Transceiver Station (BTS), qualifying as capital goods eligible for CENVAT credit. Extended period of limitation not invokable as no evidence of suppression with intent to evade tax. Appeal allowed.
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