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...
Condonation of delay in filing appeal - The Commissioner (Appeals) can only condone the delay in filing an appeal if the same is barred by one month and the Commissioner is not having any power to condone the delay in filing the appeal after expiry of 30 days period. - no illegality is committed by the appellate authority in dismissing the appeal on the ground of limitation. - HC
Condonation of delay in filing appeal - The Commissioner (Appeals) can only condone the delay in filing an appeal if the same is barred by one month and the Commissioner is not having any power to condone the delay in filing the appeal after expiry of 30 days period. - no illegality is committed by the appellate authority in dismissing the appeal on the ground of limitation. - HC
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