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...
CESTAT held banking charges paid for obtaining bank guarantee related to VAT refund on exported goods qualified as eligible input services for CENVAT credit. The services were found to satisfy both the 'means' and 'inclusion' parts of Rule 2(l) definition of input services, being connected to procurement of raw materials used in manufacturing. The Tribunal rejected the department's contention that services were not directly related to manufacturing, ruling that indirect connection through raw materials was sufficient. Extended period limitation and penalties were struck down as the matter involved interpretation of law. The appeal was allowed, setting aside the original order denying CENVAT credit.
CESTAT held banking charges paid for obtaining bank guarantee related to VAT refund on exported goods qualified as eligible input services for CENVAT credit. The services were found to satisfy both the 'means' and 'inclusion' parts of Rule 2(l) definition of input services, being connected to procurement of raw materials used in manufacturing. The Tribunal rejected the department's contention that services were not directly related to manufacturing, ruling that indirect connection through raw materials was sufficient. Extended period limitation and penalties were struck down as the matter involved interpretation of law. The appeal was allowed, setting aside the original order denying CENVAT credit.
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