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 dismissed the appellant's appeal as time-barred, holding that non-service of the adjudication order resulted from the appellant's own negligence. The appellant had vacated its old business premises and surrendered its Import Export License but failed to intimate the Department or the concerned post office regarding the change of address or to arrange redirection of mail. The Tribunal found no evidence of any timely steps to obtain the order after learning of its existence, including the unexplained delay before filing an RTI application. Distinguishing precedent where change of address had been duly notified, CESTAT held there was no sufficient cause to override limitation and sustained the impugned order.
CESTAT dismissed the appellant's appeal as time-barred, holding that non-service of the adjudication order resulted from the appellant's own negligence. The appellant had vacated its old business premises and surrendered its Import Export License but failed to intimate the Department or the concerned post office regarding the change of address or to arrange redirection of mail. The Tribunal found no evidence of any timely steps to obtain the order after learning of its existence, including the unexplained delay before filing an RTI application. Distinguishing precedent where change of address had been duly notified, CESTAT held there was no sufficient cause to override limitation and sustained the impugned order.
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