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 dismissed the appeal, holding that the appellant (a 100% EOU) unlawfully availed CENVAT credit on exempted services and failed to reverse the full ineligible credit by the prescribed date under Rule 6(3A) of the Cenvat Credit Rules, 2004. The Tribunal affirmed that where common credit is used, reversal of the portion attributable to exempted services was required on or before 30 June of the relevant year, and delay attracts interest under Rule 6(3A). The appellant's partial reversal on 2 June 2009 and belated balance reversal on 30 September 2009 gave rise to interest liability from the stipulated date until actual reversal; the impugned order was accordingly upheld.
CESTAT dismissed the appeal, holding that the appellant (a 100% EOU) unlawfully availed CENVAT credit on exempted services and failed to reverse the full ineligible credit by the prescribed date under Rule 6(3A) of the Cenvat Credit Rules, 2004. The Tribunal affirmed that where common credit is used, reversal of the portion attributable to exempted services was required on or before 30 June of the relevant year, and delay attracts interest under Rule 6(3A). The appellant's partial reversal on 2 June 2009 and belated balance reversal on 30 September 2009 gave rise to interest liability from the stipulated date until actual reversal; the impugned order was accordingly upheld.
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TaxTMI 
TaxTMI 
of 4918 
