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...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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Jurisdiction - proper authority to sign the application - In the instant case, the appeal was filed within time and there was only delay in rectification of defect pointed out by the Registry. Even otherwise, the primary objection of the Ld. Counsel for the respondent regarding the condonation of delay application being signed by an officer not authorized by Committee of Commissioners is misplaced as the requirement of filing of appeal under Section 35B is only for filing the appeals and not for other miscellaneous applications - Since there is no delay in filing the appeal, the applications for condonation of delay are dismissed as infructuous. - AT
Jurisdiction - proper authority to sign the application - In the instant case, the appeal was filed within time and there was only delay in rectification of defect pointed out by the Registry. Even otherwise, the primary objection of the Ld. Counsel for the respondent regarding the condonation of delay application being signed by an officer not authorized by Committee of Commissioners is misplaced as the requirement of filing of appeal under Section 35B is only for filing the appeals and not for other miscellaneous applications - Since there is no delay in filing the appeal, the applications for condonation of delay are dismissed as infructuous. - AT
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