Cost-to-cost reimbursement of seconded employees is not service consideration; transfer-pricing markup was deleted and amalgamation amortisation allow...
Crystallisation of liability supports prior-period expense deduction, while functionally distinct divisions require separate transfer-pricing benchmar...
Functional comparability under TNMM requires transaction-specific FAR analysis before benchmarking business-support services provided to associated en...
Advance pricing agreement methodology can guide benchmarking for non-covered years when functions, assets, risks and activities remain materially unch...
Tax-audit exemption for substantially State-funded educational universities prevents audit-failure penalties where income qualifies for statutory exem...
Functional, asset and risk analysis excludes diversified technology companies from captive software development comparables under cost-plus arrangemen...
Mobile-phone electronic evidence failed to establish customs undervaluation, while duty survived on non-authentic origin certificates without importer...
Packing materials used to market packaged tea qualify as inputs...
Packing-material input credits support inverted-duty refunds for packaged tea, while rate-reduction and concessional-supply circulars remain inapplicable.
Contents
Summary
Note
Bookmark
Share
✓ Copied successfully !
Print
Print Options
For full text, please login
Login to TaxTMI
Verification Pending
The Email Id has not been verified. Click on the link we have sent on
Packing materials used to market packaged tea qualify as inputs used in the course or furtherance of business, without a statutory distinction between principal and ancillary inputs. Their higher tax rate, despite bulk and packaged tea attracting the same rate, supports refund of accumulated input tax credit under the inverted duty structure. Circulars addressing rate reductions on the same goods at different times and supplies under concessional notifications do not apply to this situation. Executive circulars cannot expand or restrict statutory refund entitlement. Revenue appeals challenging refunds of accumulated input tax credit on eligible packing materials were dismissed.
Packing materials used to market packaged tea qualify as inputs used in the course or furtherance of business, without a statutory distinction between principal and ancillary inputs. Their higher tax rate, despite bulk and packaged tea attracting the same rate, supports refund of accumulated input tax credit under the inverted duty structure. Circulars addressing rate reductions on the same goods at different times and supplies under concessional notifications do not apply to this situation. Executive circulars cannot expand or restrict statutory refund entitlement. Revenue appeals challenging refunds of accumulated input tax credit on eligible packing materials were dismissed.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
TaxTMI 
of 4913 
