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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Refund claims arising from an appellate order must be filed within one year from the date of that order under Section 27(1B)(b); the later filing here was therefore time-barred. The Tribunal also held that Section 26 did not apply because the case was not one of return or re-importation of exported goods, and in any event that provision contained its own time requirement, which was not met. The pending Revenue appeal did not alter the statutory limitation period. The rejection of the refund application on limitation grounds was upheld.
Refund claims arising from an appellate order must be filed within one year from the date of that order under Section 27(1B)(b); the later filing here was therefore time-barred. The Tribunal also held that Section 26 did not apply because the case was not one of return or re-importation of exported goods, and in any event that provision contained its own time requirement, which was not met. The pending Revenue appeal did not alter the statutory limitation period. The rejection of the refund application on limitation grounds was upheld.
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