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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Condonation of delay in filing appeals against AAR orders is limited to a maximum extension of 30 days beyond the normal 30 day appeal period; the Appellate Authority (AAAR) lacks power to extend beyond that statutory window, so appeals filed beyond that limit must be rejected as time barred without consideration of merits. Rule permitting manual filing where electronic filing is prescribed does not excuse delay caused by non uploading of an order on the portal. The note also records the classificatory issue that transactions in immovable property may be outside Schedule III but treated as a service under Schedule II clause 5(e), though merits were not reached due to time bar.
Condonation of delay in filing appeals against AAR orders is limited to a maximum extension of 30 days beyond the normal 30 day appeal period; the Appellate Authority (AAAR) lacks power to extend beyond that statutory window, so appeals filed beyond that limit must be rejected as time barred without consideration of merits. Rule permitting manual filing where electronic filing is prescribed does not excuse delay caused by non uploading of an order on the portal. The note also records the classificatory issue that transactions in immovable property may be outside Schedule III but treated as a service under Schedule II clause 5(e), though merits were not reached due to time bar.
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