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...
Functional comparability governs software-service benchmarking: dissimilar companies are excluded, while related-party filters, margins and working-ca...
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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