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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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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