Working-capital adjustment determines whether software-services transfer-pricing margins fall within the statutory tolerance range, eliminating any ad...
Permanent establishment deductions upheld for expatriate salaries, direct costs and trading losses, while head-office costs require fresh classificati...
Data transmission equipment classification under CTSH 8517 62 remains distinct from residual classification, with exemption evidence requiring scrutin...
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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