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...
Input services like clearances charges, consultancy charges, insurance charges, GTA charges and erection/commissioning charges used by a manufacturer, directly or indirectly, in relation to manufacture of final product or clearance of final product up to place of removal, are eligible for CENVAT credit u/r 2(l)(ii) of CENVAT Credit Rules, 2004. Even though the term "setting up" was deleted from the inclusion clause, these services are covered under the main clause as input services. The Tribunal relied on the Piramal Glass Ltd case, allowing CENVAT credit on such services used for installation of a new furnace, being directly related to manufacture. The impugned order denying credit was set aside, and the appeal was allowed.
Input services like clearances charges, consultancy charges, insurance charges, GTA charges and erection/commissioning charges used by a manufacturer, directly or indirectly, in relation to manufacture of final product or clearance of final product up to place of removal, are eligible for CENVAT credit u/r 2(l)(ii) of CENVAT Credit Rules, 2004. Even though the term "setting up" was deleted from the inclusion clause, these services are covered under the main clause as input services. The Tribunal relied on the Piramal Glass Ltd case, allowing CENVAT credit on such services used for installation of a new furnace, being directly related to manufacture. The impugned order denying credit was set aside, and the appeal was allowed.
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