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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CESTAT affirmed dismissal of the appeals for want of limitation, holding that the appeals were lodged beyond the statutory period for filing appeals from Orders-in-Original and beyond the single-month condonation power vested in the Commissioner (Appeals). The Tribunal found no jurisdictional defect in the Commissioner's limitation ruling and rejected appellants' procedural objections to service/receipt as insufficient to extend time. Prior coordinate bench decisions addressing unauthorized receipt or communication failures were considered but distinguished or held inapplicable. Because the appeals were time-barred and no sufficient cause for extension within the statutory proviso was shown, the appeals were dismissed with no adjudication on merits.
CESTAT affirmed dismissal of the appeals for want of limitation, holding that the appeals were lodged beyond the statutory period for filing appeals from Orders-in-Original and beyond the single-month condonation power vested in the Commissioner (Appeals). The Tribunal found no jurisdictional defect in the Commissioner's limitation ruling and rejected appellants' procedural objections to service/receipt as insufficient to extend time. Prior coordinate bench decisions addressing unauthorized receipt or communication failures were considered but distinguished or held inapplicable. Because the appeals were time-barred and no sufficient cause for extension within the statutory proviso was shown, the appeals were dismissed with no adjudication on merits.
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