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) held that the appellants did not render intermediary services for their foreign principal. The services provided by the appellants were classified as export of services, making them eligible for refund of unutilized CENVAT credit. However, the matter was remanded to the original authority to calculate the eligible refund amount based on actual foreign remittances received during the respective quarters, as the appellants failed to submit certain Foreign Inward Remittance Certificates (FIRCs). The appeals were disposed of accordingly.
The Customs, Excise and Service Tax Appellate Tribunal (CESTAT) held that the appellants did not render intermediary services for their foreign principal. The services provided by the appellants were classified as export of services, making them eligible for refund of unutilized CENVAT credit. However, the matter was remanded to the original authority to calculate the eligible refund amount based on actual foreign remittances received during the respective quarters, as the appellants failed to submit certain Foreign Inward Remittance Certificates (FIRCs). The appeals were disposed of accordingly.
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