Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
For e-filed appeals under Section 61 of the IBC, limitation is computed from the date of e-filing, in line with the NCLAT's 24.12.2022 directions issued under the NCLAT Rules, 2016. The Tribunal rejected reliance on Delhi High Court e-filing rules because no material showed they applied to NCLAT. It applied the Supreme Court's view that a statutory day runs for 24 hours from midnight, so filing after office hours does not shift the filing date to the next working day. An appeal e-filed at 9.00 p.m. on the 45th day was therefore within the condonable period, and the 15-day delay was condoned.
For e-filed appeals under Section 61 of the IBC, limitation is computed from the date of e-filing, in line with the NCLAT's 24.12.2022 directions issued under the NCLAT Rules, 2016. The Tribunal rejected reliance on Delhi High Court e-filing rules because no material showed they applied to NCLAT. It applied the Supreme Court's view that a statutory day runs for 24 hours from midnight, so filing after office hours does not shift the filing date to the next working day. An appeal e-filed at 9.00 p.m. on the 45th day was therefore within the condonable period, and the 15-day delay was condoned.
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