Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
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...
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The Supreme Court considered the Condonation of Delay in filing an appeal for compensation enhancement, analyzing the applicability of Limitation Act provisions. The Court emphasized the discretionary power of courts in condoning delay, stating that while Section 5 of the Limitation Act should be construed liberally, Section 3 must be strictly interpreted. The Court highlighted that the right of a decree-holder becomes substantive after the limitation period expires, and this right should not be lightly disturbed. The Court declined to exercise its discretionary power to condone the delay, noting the negligence of the claimants in pursuing the appeal and the lack of due diligence. The High Court's decision not to condone the delay was upheld, and the Special Leave Petition was dismissed for lacking merit.
The Supreme Court considered the Condonation of Delay in filing an appeal for compensation enhancement, analyzing the applicability of Limitation Act provisions. The Court emphasized the discretionary power of courts in condoning delay, stating that while Section 5 of the Limitation Act should be construed liberally, Section 3 must be strictly interpreted. The Court highlighted that the right of a decree-holder becomes substantive after the limitation period expires, and this right should not be lightly disturbed. The Court declined to exercise its discretionary power to condone the delay, noting the negligence of the claimants in pursuing the appeal and the lack of due diligence. The High Court's decision not to condone the delay was upheld, and the Special Leave Petition was dismissed for lacking merit.
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