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 HC condoned a 597-day delay in filing an appeal under Section 246A. The appellant claimed they did not receive communication of the order as it was sent to an inactive email address, and filed the appeal promptly upon discovering the order. The Court noted that the revenue department did not file any counter-affidavit to contest the appellant's explanation. Following the Supreme Court's precedent in Vidya Shankar Jaiswal, which mandates a justice-oriented approach to condonation applications, the HC condoned the delay subject to payment of Rs. 5,000/- costs to the High Court Legal Services Committee within 15 days.
The HC condoned a 597-day delay in filing an appeal under Section 246A. The appellant claimed they did not receive communication of the order as it was sent to an inactive email address, and filed the appeal promptly upon discovering the order. The Court noted that the revenue department did not file any counter-affidavit to contest the appellant's explanation. Following the Supreme Court's precedent in Vidya Shankar Jaiswal, which mandates a justice-oriented approach to condonation applications, the HC condoned the delay subject to payment of Rs. 5,000/- costs to the High Court Legal Services Committee within 15 days.
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