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...
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.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
