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...
Job Work: The Tribunal observed that there was no evidence to substantiate the allegation that the appellant carried out activities amounting to 'manufacture' such as quality testing or labelling at their premises. Without identification and quantification of the goods allegedly manufactured, the show cause notice was deemed ex-facie bad in law. Consequently, the demand for central excise duty, interest, and penalties imposed on the appellant company and its partner were set aside. The Tribunal further held that since no suppression of facts with the intention to evade tax was established, invoking the extended period of limitation to demand duty was legally unsustainable.
Job Work: The Tribunal observed that there was no evidence to substantiate the allegation that the appellant carried out activities amounting to 'manufacture' such as quality testing or labelling at their premises. Without identification and quantification of the goods allegedly manufactured, the show cause notice was deemed ex-facie bad in law. Consequently, the demand for central excise duty, interest, and penalties imposed on the appellant company and its partner were set aside. The Tribunal further held that since no suppression of facts with the intention to evade tax was established, invoking the extended period of limitation to demand duty was legally unsustainable.
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