Transfer pricing comparability requires functional alignment, reliable financial data, and careful review of working capital and receivables adjustmen...
Transfer pricing rules require benchmarking corporate guarantees and associated-enterprise advances, while invalid domestic-transaction adjustments ca...
Prospective sugar export prohibition required registered letters of credit; private contracts and export quotas created no enforceable continuation ri...
Retroactive interim-moratorium exclusion permits protective asset disclosure and preservation measures against personal guarantors pending arbitration...
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Condonation of delay in filing appeal before Commissioner (Appeals) - time limitation - The appellant received the order on 30.12.2018, making the appeal filed on 22.04.2019 beyond the prescribed period. The contention that the limitation should commence from 22.02.2019, based on subsequent correspondence, was rejected as the order's date remained 14.12.2018, and communication after the order's issuance couldn't alter the appeal timeline. - Consequently, the tribunal dismissed the appeal of the assessee.
Condonation of delay in filing appeal before Commissioner (Appeals) - time limitation - The appellant received the order on 30.12.2018, making the appeal filed on 22.04.2019 beyond the prescribed period. The contention that the limitation should commence from 22.02.2019, based on subsequent correspondence, was rejected as the order's date remained 14.12.2018, and communication after the order's issuance couldn't alter the appeal timeline. - Consequently, the tribunal dismissed the appeal of the assessee.
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