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 an appeal under the Insolvency and Bankruptcy Code runs from the date the impugned order is pronounced in open court, not from the date it is uploaded, received, or actually known to the appellant. Where pronouncement is established, a party must act diligently, apply for a certified copy, and can claim only the statutory exclusion for time requisite to obtain it. The appellate tribunal also reiterated that the condonable period under the appeal provision is strictly confined to thirty days plus a further fifteen days; no equitable extension is available beyond that outer limit. On that basis, both appeals filed after the limit were treated as time-barred and the delay applications were rejected.
Limitation for an appeal under the Insolvency and Bankruptcy Code runs from the date the impugned order is pronounced in open court, not from the date it is uploaded, received, or actually known to the appellant. Where pronouncement is established, a party must act diligently, apply for a certified copy, and can claim only the statutory exclusion for time requisite to obtain it. The appellate tribunal also reiterated that the condonable period under the appeal provision is strictly confined to thirty days plus a further fifteen days; no equitable extension is available beyond that outer limit. On that basis, both appeals filed after the limit were treated as time-barred and the delay applications were rejected.
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