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 CESTAT held that the one-year period for filing a refund claim u/r 5 of the CENVAT Credit Rules, 2004, for exports made on a quarterly basis, commences from the end of the quarter in which the foreign exchange is received. Since the appellant filed the refund claim on 28.03.2018, within one year from the end of the quarter January-March 2017, the rejection of the refund of Rs. 93,39,310/- was not tenable. Consequently, the appeal was allowed.
The CESTAT held that the one-year period for filing a refund claim u/r 5 of the CENVAT Credit Rules, 2004, for exports made on a quarterly basis, commences from the end of the quarter in which the foreign exchange is received. Since the appellant filed the refund claim on 28.03.2018, within one year from the end of the quarter January-March 2017, the rejection of the refund of Rs. 93,39,310/- was not tenable. Consequently, the appeal was allowed.
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