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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SC rejected the interim application under Section 5 of Limitation Act, 1963, declining to condone 301 days delay in filing commercial appeal. The Court emphasized the Commercial Courts Act's objective of expediting commercial litigation and strict adherence to statutory timelines. The petitioner's failure to procure certified copies within prescribed limitation period and subsequent 300-day inaction was deemed negligent. The limitation period commenced from judgment pronouncement, irrespective of certified copy provision. The Court underscored that parties cannot evade procedural responsibilities, and such interpretation would undermine limitation principles and the Act's purpose of ensuring timely case disposal. Consequently, the petition was dismissed, upholding the lower court's rejection of delay condonation.
SC rejected the interim application under Section 5 of Limitation Act, 1963, declining to condone 301 days delay in filing commercial appeal. The Court emphasized the Commercial Courts Act's objective of expediting commercial litigation and strict adherence to statutory timelines. The petitioner's failure to procure certified copies within prescribed limitation period and subsequent 300-day inaction was deemed negligent. The limitation period commenced from judgment pronouncement, irrespective of certified copy provision. The Court underscored that parties cannot evade procedural responsibilities, and such interpretation would undermine limitation principles and the Act's purpose of ensuring timely case disposal. Consequently, the petition was dismissed, upholding the lower court's rejection of delay condonation.
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