Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
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Section 112(3) confines the prescribed limitation period to filing an appeal before the Tribunal and does not impose a separate six-month deadline on the Commissioner to review the first appellate order. A departmental appeal filed within the applicable extended filing period therefore remains maintainable even where the Commissioner's review occurred after six months. The maintainability objection was rejected, and the appeal was admitted for adjudication on merits.
Section 112(3) confines the prescribed limitation period to filing an appeal before the Tribunal and does not impose a separate six-month deadline on the Commissioner to review the first appellate order. A departmental appeal filed within the applicable extended filing period therefore remains maintainable even where the Commissioner's review occurred after six months. The maintainability objection was rejected, and the appeal was admitted for adjudication on merits.
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