Reopening of assessment cannot rest solely on an audit party's opinion; reassessment under Section 147/148 is impermissible and power of revision shou...
Tested party selection: functional analysis identified the least complex unit as the appropriate tested party, altering the transfer pricing adjustmen...
Refund claim of Cenvat credit for input services used in export was contested on realization of export proceeds; the article explains that payment received in Indian rupees from a foreign bank account through authorised banking channels (including Vostro accounts) constitutes deemed repatriation of realized foreign exchange and may be evidenced by a Foreign Inward Remittance Certificate. Applying the tribunal ratio cited, the condition for export realisation is satisfied and orders denying the refund were set aside, with consequential reliefs as per law.
Refund claim of Cenvat credit for input services used in export was contested on realization of export proceeds; the article explains that payment received in Indian rupees from a foreign bank account through authorised banking channels (including Vostro accounts) constitutes deemed repatriation of realized foreign exchange and may be evidenced by a Foreign Inward Remittance Certificate. Applying the tribunal ratio cited, the condition for export realisation is satisfied and orders denying the refund were set aside, with consequential reliefs as per law.
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