Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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