Classification of imported salvaged shaft pieces as ship parts confirmed, reassessment time-barred and appeal allowed restoring original classificatio...
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CENVAT credit availability after omission of Rule 12B in textiles confirmed; late addendum to SCN introducing new grounds held time-barred and invalid...
Transfer pricing adjustment was confined to international transactions with the associated enterprise, consistent with the settled view that arm's length pricing under transfer pricing provisions cannot be extended to the assessee's entire when the dispute concerns only controlled transactions. The Tribunal also sustained directions on capacity utilisation and working capital adjustments, noting that both claims had been verified and allowed on facts, leaving no surviving grievance for interference. It further upheld uniform operating treatment of forex gain and provision write-back for transfer pricing purposes, finding no basis to depart from consistency. The Revenue's challenges on all these issues were dismissed.
Transfer pricing adjustment was confined to international transactions with the associated enterprise, consistent with the settled view that arm's length pricing under transfer pricing provisions cannot be extended to the assessee's entire when the dispute concerns only controlled transactions. The Tribunal also sustained directions on capacity utilisation and working capital adjustments, noting that both claims had been verified and allowed on facts, leaving no surviving grievance for interference. It further upheld uniform operating treatment of forex gain and provision write-back for transfer pricing purposes, finding no basis to depart from consistency. The Revenue's challenges on all these issues were dismissed.
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