Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Service of an adjudication order on an authorised representative was treated as valid communication under the governing service provision, and the appeal period was counted from that date. Because the appeal to the Commissioner (Appeals) was filed after the statutory limit and beyond the condonable extension, the majority held it to be time-barred and not maintainable. The contrary view that the appeal should be examined on merits was rejected, and the dismissal for limitation was upheld.
Service of an adjudication order on an authorised representative was treated as valid communication under the governing service provision, and the appeal period was counted from that date. Because the appeal to the Commissioner (Appeals) was filed after the statutory limit and beyond the condonable extension, the majority held it to be time-barred and not maintainable. The contrary view that the appeal should be examined on merits was rejected, and the dismissal for limitation was upheld.
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