Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Appellant not liable for service tax under 'Business Support Service' category as it exported its own goods, not providing support services to another entity. CENVAT credit on club membership fees allowed as meetings organized for sales promotion activities. Suo-moto re-credit to CENVAT account without documentary evidence not permissible. No penalty imposable as tax paid before show cause notice. Demand barred by limitation as periodical audits conducted. Impugned order set aside, appeal allowed.
Appellant not liable for service tax under 'Business Support Service' category as it exported its own goods, not providing support services to another entity. CENVAT credit on club membership fees allowed as meetings organized for sales promotion activities. Suo-moto re-credit to CENVAT account without documentary evidence not permissible. No penalty imposable as tax paid before show cause notice. Demand barred by limitation as periodical audits conducted. Impugned order set aside, appeal allowed.
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