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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
Time limitation for filing appeal - Suffice to say that an appeal under Section 107 is subject to a 'prescribed period of limitation' and a 'condonable period of limitation' i.e., three months and one month respectively. It is also circumscribed by a pre-deposit condition. If the writ petitioner is able to satisfy the Appellate Authority qua limitation and pre-deposit, it is open to the Appellate Authority to consider the appeal on its own merits and in accordance with law. - HC
Time limitation for filing appeal - Suffice to say that an appeal under Section 107 is subject to a 'prescribed period of limitation' and a 'condonable period of limitation' i.e., three months and one month respectively. It is also circumscribed by a pre-deposit condition. If the writ petitioner is able to satisfy the Appellate Authority qua limitation and pre-deposit, it is open to the Appellate Authority to consider the appeal on its own merits and in accordance with law. - HC
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