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 an appeal before the appellate authority - Applicability of Section 5 of the Limitation Act, 1963 - Power and Jurisdiction of appellate authority to condone the delay beyond the prescribed period - The High court concluded that the appellate authority has the power to condone delays beyond the one-month extension provided in Section 107(4) of the Act. The court held that the appellate authority's refusal to entertain the delay application constituted a failure to exercise its jurisdiction.
Condonation of delay in filing an appeal before the appellate authority - Applicability of Section 5 of the Limitation Act, 1963 - Power and Jurisdiction of appellate authority to condone the delay beyond the prescribed period - The High court concluded that the appellate authority has the power to condone delays beyond the one-month extension provided in Section 107(4) of the Act. The court held that the appellate authority's refusal to entertain the delay application constituted a failure to exercise its jurisdiction.
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