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 CESTAT upheld the dismissal of the appeal due to delay exceeding the prescribed limitation period. The appellant sought condonation of delay beyond four months, citing poor business conditions and inability to deposit the pre-deposit amount as reasons. The Commissioner (Appeal) correctly held that the appeal was filed beyond the two-month period allowed by law and that only one month's delay could be condoned for sufficient cause. The Tribunal affirmed that the Commissioner (Appeal) lacked jurisdiction to condone delay beyond thirty days and found no merit in the appellant's grounds. Consequently, the appeal was dismissed for being time-barred.
The CESTAT upheld the dismissal of the appeal due to delay exceeding the prescribed limitation period. The appellant sought condonation of delay beyond four months, citing poor business conditions and inability to deposit the pre-deposit amount as reasons. The Commissioner (Appeal) correctly held that the appeal was filed beyond the two-month period allowed by law and that only one month's delay could be condoned for sufficient cause. The Tribunal affirmed that the Commissioner (Appeal) lacked jurisdiction to condone delay beyond thirty days and found no merit in the appellant's grounds. Consequently, the appeal was dismissed for being time-barred.
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