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 allowed the appeal and set aside the impugned demand and penalties. It held that CENVAT credit on services (erection/commissioning/installation) received at the appellant's depot/brand shop falls within the statutory definition of input services up to the place of removal and therefore could not be denied. The Tribunal rejected reliance on inapposite authorities concerning GTA services. A recovery was sustained only to the extent already voluntarily reversed by the appellant for Feb 2013-Jan 2014 (with interest); demands for earlier periods were quashed for lack of facts justifying invocation of the extended period of limitation and, consequently, penalties were also rescinded. The appeal was allowed.
CESTAT allowed the appeal and set aside the impugned demand and penalties. It held that CENVAT credit on services (erection/commissioning/installation) received at the appellant's depot/brand shop falls within the statutory definition of input services up to the place of removal and therefore could not be denied. The Tribunal rejected reliance on inapposite authorities concerning GTA services. A recovery was sustained only to the extent already voluntarily reversed by the appellant for Feb 2013-Jan 2014 (with interest); demands for earlier periods were quashed for lack of facts justifying invocation of the extended period of limitation and, consequently, penalties were also rescinded. The appeal was allowed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4918 
