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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Cancellation/suspension of registration of petitioner - delay of 865 days in filing appeal - The limitation under Section 107 of the Act of 2017 is three months which is evident from the perusal of the statutory provision contained in Section 107 of the Act of 2017. However, Section 29 of the Act of 2017 is entirely different and only deals with the application for revocation of cancellation of registration. - The reasoning given by the lower Appellate Authority are just and proper. Circular issued by the CBIC is of no assistance to petitioner inasmuch as the same only deals with Section 29 of the Act of 2017 and not with Section 107 of the Act of 2017 - HC
Cancellation/suspension of registration of petitioner - delay of 865 days in filing appeal - The limitation under Section 107 of the Act of 2017 is three months which is evident from the perusal of the statutory provision contained in Section 107 of the Act of 2017. However, Section 29 of the Act of 2017 is entirely different and only deals with the application for revocation of cancellation of registration. - The reasoning given by the lower Appellate Authority are just and proper. Circular issued by the CBIC is of no assistance to petitioner inasmuch as the same only deals with Section 29 of the Act of 2017 and not with Section 107 of the Act of 2017 - HC
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