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...
The Customs, Excise and Service Tax Appellate Tribunal (CESTAT) dismissed the Revenue's appeal. It held that the transaction between the parties constituted a job work arrangement, not a 'supply of tangible goods for use service'. The respondent installed machinery at the client's factory premises to carry out production activities using their own machines. No lease rent or consideration was charged for the 'supply of tangible goods for use'. The charges collected were for the production process on a job work basis, as evident from the invoices. Therefore, the demand of service tax under the 'supply of tangible goods for use service' was incorrect.
The Customs, Excise and Service Tax Appellate Tribunal (CESTAT) dismissed the Revenue's appeal. It held that the transaction between the parties constituted a job work arrangement, not a 'supply of tangible goods for use service'. The respondent installed machinery at the client's factory premises to carry out production activities using their own machines. No lease rent or consideration was charged for the 'supply of tangible goods for use'. The charges collected were for the production process on a job work basis, as evident from the invoices. Therefore, the demand of service tax under the 'supply of tangible goods for use service' was incorrect.
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