Pre-amendment reassessment limitation bars late notices under the preserved regime, invalidating consequential reassessment for affected earlier asses...
Cash-sales explanations for bank deposits require documentary reconciliation; reassessment notice survived where effective response time was available...
Functional comparability in transfer pricing prevents ad hoc arm's length adjustments where functions, assets, risks and reliable comparables are unes...
Contingency expenses, exempt-income disallowance, and royalty benchmarking: unsupported adjustments were deleted under consistent accounting and trans...
CESTAT ruled in favor of appellant regarding CENVAT credit eligibility for electrical transmission tower materials and related services. The tribunal held that transmission towers qualify as components/accessories of capital goods under Rule 2(a)(A) of CENVAT Credit Rules, 2004. Health insurance and supervision services were deemed eligible input services. While appellant must reverse Rs.25,544 with interest, the larger credit amount of Rs.9,40,359 was allowed. Extended period limitation invocation was invalidated due to absence of evidence showing suppression intent. Penalties were set aside. The ruling aligned with Supreme Court precedent in similar cases regarding treatment of transmission equipment as capital goods components.
CESTAT ruled in favor of appellant regarding CENVAT credit eligibility for electrical transmission tower materials and related services. The tribunal held that transmission towers qualify as components/accessories of capital goods under Rule 2(a)(A) of CENVAT Credit Rules, 2004. Health insurance and supervision services were deemed eligible input services. While appellant must reverse Rs.25,544 with interest, the larger credit amount of Rs.9,40,359 was allowed. Extended period limitation invocation was invalidated due to absence of evidence showing suppression intent. Penalties were set aside. The ruling aligned with Supreme Court precedent in similar cases regarding treatment of transmission equipment as capital goods components.
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