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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Delay in re-filing a company appeal was not condoned because the appellant failed to show sufficient cause or due diligence in curing defects. The NCLAT held that, especially in insolvency matters, re-filing delays must be assessed strictly in light of the Code's time-bound framework, and generic explanations such as re-pagination, paper-book restructuring, rescanning, and internal record retrieval are inadequate without material particulars. Here, no defect sheet, specific Registry objections, or date-wise chronology of corrective steps was produced, and the claim that records were in Mumbai was treated as a bare logistical inconvenience. The application for condonation was rejected, and the appeal was consequently rejected.
Delay in re-filing a company appeal was not condoned because the appellant failed to show sufficient cause or due diligence in curing defects. The NCLAT held that, especially in insolvency matters, re-filing delays must be assessed strictly in light of the Code's time-bound framework, and generic explanations such as re-pagination, paper-book restructuring, rescanning, and internal record retrieval are inadequate without material particulars. Here, no defect sheet, specific Registry objections, or date-wise chronology of corrective steps was produced, and the claim that records were in Mumbai was treated as a bare logistical inconvenience. The application for condonation was rejected, and the appeal was consequently rejected.
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