Transfer pricing comparables and adjustments: Tribunal revisits loss-maker status, segmental comparability, working capital relief, and risk allocatio...
Business expenditure disallowance failed where commission, related-party salary and promotion payments were supported by records and inquiry was inade...
Section 128(1) of the Customs Act prescribes a mandatory 60-day period for filing an appeal, with only a further 30 days available for condonation on sufficient cause shown. Once that outer limit expires, the Commissioner (Appeals) lacks jurisdiction to admit the appeal, and section 5 of the Limitation Act is excluded. The Tribunal applied Singh Enterprises and upheld dismissal of the appeal as time-barred, holding that alleged natural justice violations could not be examined outside the statutory appeal window.
Section 128(1) of the Customs Act prescribes a mandatory 60-day period for filing an appeal, with only a further 30 days available for condonation on sufficient cause shown. Once that outer limit expires, the Commissioner (Appeals) lacks jurisdiction to admit the appeal, and section 5 of the Limitation Act is excluded. The Tribunal applied Singh Enterprises and upheld dismissal of the appeal as time-barred, holding that alleged natural justice violations could not be examined outside the statutory appeal window.
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