Functional comparability under TNMM supported exclusion of ITeS comparables with R&D, intangibles, diversified operations, or unavailable segmental da...
Functional comparability governs selection of support-service and IT-enabled service comparables, with verification required for unresolved data and m...
The case involved a Stay petition u/s Order-in-Appeal setting aside a fine for late filing of Bill of Entry. Appellant faced technical glitches while filing through ICEGATE, leading to automatic imposition of fine. Despite efforts to file on time, technical issues prevented timely submission. Commissioner (Appeals) considered documentary evidence and relied on precedent (M/S. BLUELEAF TRADING COMPANY case) to conclude no mala fide intent. The Tribunal found no reason to interfere with the Commissioner's decision, dismissing the Revenue's appeal.
The case involved a Stay petition u/s Order-in-Appeal setting aside a fine for late filing of Bill of Entry. Appellant faced technical glitches while filing through ICEGATE, leading to automatic imposition of fine. Despite efforts to file on time, technical issues prevented timely submission. Commissioner (Appeals) considered documentary evidence and relied on precedent (M/S. BLUELEAF TRADING COMPANY case) to conclude no mala fide intent. The Tribunal found no reason to interfere with the Commissioner's decision, dismissing the Revenue's appeal.
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