Interest on Wrongful Input Tax Credit is mandatory where excess transitional credit was retained and later reversed, and related objections were rejec...
Reopening Assessments invalid where satisfaction and jurisdictional approval are absent for third party seized material, leading to quashing of assess...
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Disallowance of interest was contested on the ground that short-term borrowings were used for long-term investment and only a limited period of capitalization was warranted. Relying on the audit report evidencing diversion of short-term loans to capital projects already put to use, and noting that capital work-in-progress was undisputed, the appellate authority correctly sustained capitalization of interest only for four months and deleted the balance disallowance; the revenue's challenge was rejected. On transfer pricing for sugar exports, CUP-based benchmarking using FOB-converted prices with an average of NYBOT and Kingsman rates, along with the statutory tolerance range under section 92C(2), was upheld; no interference was warranted. On ferrous exports, contracts were accepted as CUP and adjustment restricted; the revenue's ground failed. - ITAT
Disallowance of interest was contested on the ground that short-term borrowings were used for long-term investment and only a limited period of capitalization was warranted. Relying on the audit report evidencing diversion of short-term loans to capital projects already put to use, and noting that capital work-in-progress was undisputed, the appellate authority correctly sustained capitalization of interest only for four months and deleted the balance disallowance; the revenue's challenge was rejected. On transfer pricing for sugar exports, CUP-based benchmarking using FOB-converted prices with an average of NYBOT and Kingsman rates, along with the statutory tolerance range under section 92C(2), was upheld; no interference was warranted. On ferrous exports, contracts were accepted as CUP and adjustment restricted; the revenue's ground failed. - ITAT
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