Transfer pricing comparables and operating income principles applied to software development services, with exclusions, inclusions, and tax credit ver...
Transfer pricing on performance guarantees and overdue receivables deleted where warranty obligations were embedded and working capital adjustment alr...
Service of the Order-in-Original was proved by clear acknowledgement dated 07.02.2023, and the appellant's production of the signed order itself undermined the claim of late receipt. On that factual basis, the appeal filed before the Commissioner (Appeals) on 30.01.2025 was held to be far beyond the normal and statutorily condonable period. Applying Singh Enterprises, the Tribunal held that the Commissioner (Appeals), as a creature of statute, had no power to condone delay beyond the period expressly permitted by law. The plea on delayed service failed, and the appeal was dismissed as time-barred without examination of the merits.
Service of the Order-in-Original was proved by clear acknowledgement dated 07.02.2023, and the appellant's production of the signed order itself undermined the claim of late receipt. On that factual basis, the appeal filed before the Commissioner (Appeals) on 30.01.2025 was held to be far beyond the normal and statutorily condonable period. Applying Singh Enterprises, the Tribunal held that the Commissioner (Appeals), as a creature of statute, had no power to condone delay beyond the period expressly permitted by law. The plea on delayed service failed, and the appeal was dismissed as time-barred without examination of the merits.
Note: It is a system-generated summary and is for quick reference only.
TaxTMI 
of 4805
Join Channel
TaxTMI 
