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 appellant filed an appeal under Section 61 of the IBC challenging an order dated 07.01.2025. The Tribunal held that the limitation period for filing such an appeal commences from the date of pronouncement of the impugned order, not from the appellant's knowledge thereof. The 30-day limitation period expired on 06.02.2025, with an additional 15-day condonable delay ending on 21.02.2025. The appeal was filed on 09.04.2025, well beyond the permissible period. Relying on Supreme Court precedent, the Tribunal found no jurisdiction to condone the delay and dismissed the appeal. Consequently, the request for condonation of delay was refused, resulting in the appeal's dismissal for being time-barred.
The appellant filed an appeal under Section 61 of the IBC challenging an order dated 07.01.2025. The Tribunal held that the limitation period for filing such an appeal commences from the date of pronouncement of the impugned order, not from the appellant's knowledge thereof. The 30-day limitation period expired on 06.02.2025, with an additional 15-day condonable delay ending on 21.02.2025. The appeal was filed on 09.04.2025, well beyond the permissible period. Relying on Supreme Court precedent, the Tribunal found no jurisdiction to condone the delay and dismissed the appeal. Consequently, the request for condonation of delay was refused, resulting in the appeal's dismissal for being time-barred.
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