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...
HC quashed show cause notice due to unreasonable delay in adjudication spanning two decades. Department's internal CERA audit objection and conflicting views among Central Excise Officers led to prolonged inaction until January 2021. Court found petitioner had properly discharged service tax liability under works contract service per Section 65(95)(ZZZA) of Finance Act, 1994. Department's own Statement of Facts acknowledged disagreement with CERA audit findings. HC ordered refund of excess amounts deposited during investigation with 6% interest from payment date. Court affirmed petitioner's right to modify valuation method for service tax payment under Finance Act provisions.
HC quashed show cause notice due to unreasonable delay in adjudication spanning two decades. Department's internal CERA audit objection and conflicting views among Central Excise Officers led to prolonged inaction until January 2021. Court found petitioner had properly discharged service tax liability under works contract service per Section 65(95)(ZZZA) of Finance Act, 1994. Department's own Statement of Facts acknowledged disagreement with CERA audit findings. HC ordered refund of excess amounts deposited during investigation with 6% interest from payment date. Court affirmed petitioner's right to modify valuation method for service tax payment under Finance Act provisions.
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