Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
The appellant's refund claims were allowed by the CESTAT. For notification No.12/2012-C.E., the condition inserted later in 2015 was not applicable for the relevant period of March 2013, entitling the appellant to exemption. Regarding notification No.108/95-C.E., the belated production of the required certificate was a condonable procedural lapse, and the exemption was allowed as the goods were intended for the specified use. The Chartered Accountant's certificate was accepted as sufficient proof against unjust enrichment. The impugned order was set aside, and the appeal was allowed.
The appellant's refund claims were allowed by the CESTAT. For notification No.12/2012-C.E., the condition inserted later in 2015 was not applicable for the relevant period of March 2013, entitling the appellant to exemption. Regarding notification No.108/95-C.E., the belated production of the required certificate was a condonable procedural lapse, and the exemption was allowed as the goods were intended for the specified use. The Chartered Accountant's certificate was accepted as sufficient proof against unjust enrichment. The impugned order was set aside, and the appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4902 
