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...
CESTAT allowed appeal concerning CENVAT credit on input services under Rule 2(l) of CENVAT Credit Rules, 2004. Tribunal held that sales promotion and brand building services maintained direct nexus with manufacturing, qualifying for CENVAT credit. Extended limitation period was inapplicable as case involved interpretational issues of complex legal provisions. Penalty under Section 11AC and Rule 15 was invalid absent fraud or willful misstatement. Interest under Rule 14 and Section 11AA was not chargeable as conditions for erroneous credit availment were unmet. Tribunal set aside demands, interest, and penalties, noting ER-1 Returns format required only total CENVAT credit reflection, not category-wise breakdown.
CESTAT allowed appeal concerning CENVAT credit on input services under Rule 2(l) of CENVAT Credit Rules, 2004. Tribunal held that sales promotion and brand building services maintained direct nexus with manufacturing, qualifying for CENVAT credit. Extended limitation period was inapplicable as case involved interpretational issues of complex legal provisions. Penalty under Section 11AC and Rule 15 was invalid absent fraud or willful misstatement. Interest under Rule 14 and Section 11AA was not chargeable as conditions for erroneous credit availment were unmet. Tribunal set aside demands, interest, and penalties, noting ER-1 Returns format required only total CENVAT credit reflection, not category-wise breakdown.
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