Service permanent establishment requires non-auxiliary services, while arm's-length distributor remuneration precludes further profit attribution in I...
Make-available condition excludes standard SaaS subscription receipts where customers receive no independently usable technical knowledge after subscr...
Anonymous donation classification fails where charitable trusts maintain undisputed donor identity records and evidence corpus contributions' intended...
Transfer pricing method selection favours TNMM where medical-equipment distribution involves substantial post-import value addition and operational ri...
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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