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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Limitation for insolvency appeals runs from the date an NCLAT order is pronounced in open court, and later uploading of the order does not postpone the start of time. Exclusion for time taken to obtain a certified copy was unavailable because there was no showing that the appellants applied for the copy within the limitation period. As the insolvency code is a self-contained statute with only a limited condonable delay of fifteen days beyond the initial period, an appeal filed on the 46th day was beyond the maximum permissible limit and could not be entertained; the delay applications were rejected and both appeals were dismissed as time-barred.
Limitation for insolvency appeals runs from the date an NCLAT order is pronounced in open court, and later uploading of the order does not postpone the start of time. Exclusion for time taken to obtain a certified copy was unavailable because there was no showing that the appellants applied for the copy within the limitation period. As the insolvency code is a self-contained statute with only a limited condonable delay of fifteen days beyond the initial period, an appeal filed on the 46th day was beyond the maximum permissible limit and could not be entertained; the delay applications were rejected and both appeals were dismissed as time-barred.
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