Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
Limitation for an appeal under section 61 of the Insolvency and Bankruptcy Code runs from the date of pronouncement of the impugned order, not from the date of upload or the appellant's date of knowledge. The tribunal applied the statutory time-bound appellate scheme and held that the order pronounced on 08.12.2025 triggered limitation from that date. It also held that an alleged technical glitch in the e-filing portal could not justify condonation once the appeal was filed beyond the maximum condonable period of thirty days plus fifteen days, because the tribunal lacked jurisdiction to entertain a delayed appeal on equitable or technical grounds. The condonation application and appeal were rejected as time-barred.
Limitation for an appeal under section 61 of the Insolvency and Bankruptcy Code runs from the date of pronouncement of the impugned order, not from the date of upload or the appellant's date of knowledge. The tribunal applied the statutory time-bound appellate scheme and held that the order pronounced on 08.12.2025 triggered limitation from that date. It also held that an alleged technical glitch in the e-filing portal could not justify condonation once the appeal was filed beyond the maximum condonable period of thirty days plus fifteen days, because the tribunal lacked jurisdiction to entertain a delayed appeal on equitable or technical grounds. The condonation application and appeal were rejected as time-barred.
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