Section 80JJAA employee-cost deduction allowed for deployed staff but barred against transfer-pricing income enhancement, with pricing issues remanded...
Transfer-pricing methodology protects commercially genuine associated-enterprise payments, while pre-2016 secondary adjustments and related notional i...
Negative liens over operating assets can constitute international transactions requiring arm's-length pricing reflecting restricted borrowing and expa...
Cross-examination rights in Customs Broker revocation inquiries require witness examination; procedural denial may be cured through fresh adjudication...
Governmental authority status supports construction-service exemption, while pre-cutoff contract and stamp-duty compliance requires verification on re...
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Section 107(4) of the Act allows the Appellate Authority to condone delay by permitting an appeal to be filed within an additional one month period if the appellant shows sufficient cause for missing the primary three or six month window; therefore a 15 day delay justified by non fanciful grounds cannot be defeated by a hyper technical threshold dismissal. The High Court found the respondents' insistence on an earlier cutoff date legally unsustainable, set aside the earlier order, condoned the delay, and remitted the matter to the appellate authority for adjudication on merits.
Section 107(4) of the Act allows the Appellate Authority to condone delay by permitting an appeal to be filed within an additional one month period if the appellant shows sufficient cause for missing the primary three or six month window; therefore a 15 day delay justified by non fanciful grounds cannot be defeated by a hyper technical threshold dismissal. The High Court found the respondents' insistence on an earlier cutoff date legally unsustainable, set aside the earlier order, condoned the delay, and remitted the matter to the appellate authority for adjudication on merits.
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