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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Period of limitation - Filing of appeal - apparently there was no proper service of the impugned order dated 31-01-2018 passed by the Original Authority/Assessing Authority upon the petitioner, so as to enable him to prefer an appeal before the Commissioner of Central Excise (Appeals) in accordance with Section 85 of the Act 1994. - The Hon’ble Supreme Court in catena of decisions has categorically held, that the rules of limitation are not meant to destroy the rights of the parties. The Courts are only required to ensure that, a litigant has not to take resort to dilatory tactics and has approached the Court bonafidely. - HC
Period of limitation - Filing of appeal - apparently there was no proper service of the impugned order dated 31-01-2018 passed by the Original Authority/Assessing Authority upon the petitioner, so as to enable him to prefer an appeal before the Commissioner of Central Excise (Appeals) in accordance with Section 85 of the Act 1994. - The Hon’ble Supreme Court in catena of decisions has categorically held, that the rules of limitation are not meant to destroy the rights of the parties. The Courts are only required to ensure that, a litigant has not to take resort to dilatory tactics and has approached the Court bonafidely. - HC
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