Refund Denied: No Credit for Additional Customs Duty on Inputs for Intermediaries Under Tripartite Contracts.

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....Refund claim - credit of additional duty of customs (CVD) on inputs imported - It is clear that even as per the tripartite contracts, the appellants are a sort of middle-man in respect of the services rendered by the vendors. While TI, USA receives the services rendered by the vendors and pays for the same in USD, TI, India acts only as a facilitator in receiving the money in USD from TI, USA and making payments to the Indian vendors in INR. The appellants, therefore, cannot be held to be receivers of the input services rendered by the vendors - Neither credit is to be allowed nor refund is to be allowed - AT....