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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Ibc limitation for appeals is to be computed from the day after pronouncement of the impugned order; the statutory 30 day period plus a non extendable 15 day outer limit cannot be condoned beyond that aggregate. The tribunal found that mere postal dispatch or tracking entries do not constitute effective service, and where a corporate debtor was unaware of ex parte proceedings until later contact by an interim professional, limitation may be measured from actual knowledge; however, on the facts the appeal was filed after the 45 day outer limit and the tribunal held it lacked jurisdiction to condone the delay, dismissing the condonation application.
Ibc limitation for appeals is to be computed from the day after pronouncement of the impugned order; the statutory 30 day period plus a non extendable 15 day outer limit cannot be condoned beyond that aggregate. The tribunal found that mere postal dispatch or tracking entries do not constitute effective service, and where a corporate debtor was unaware of ex parte proceedings until later contact by an interim professional, limitation may be measured from actual knowledge; however, on the facts the appeal was filed after the 45 day outer limit and the tribunal held it lacked jurisdiction to condone the delay, dismissing the condonation application.
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