Approved resolution plans extinguish unsubmitted pre-approval tax claims, preventing later recovery outside the insolvency process and preserving a cl...
Transfer pricing comparability requires functional alignment and permits working capital adjustment, while APA margins cannot govern non-covered years...
Treaty benefit, goodwill depreciation and hedging costs: export commission disallowed, while key business deductions and depreciation claims succeeded...
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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