Transfer-pricing comparability requires functional alignment; delayed associated-enterprise receivables need separate LIBOR-based benchmarking, while ...
Extended reassessment limitation in search cases requires asset-linked escaped income, invalidating additions based only on unexplained money or expen...
Enhanced tolerance band under section 43CA applies retrospectively, deleting qualifying deemed-sale additions while disputed stamp valuation requires ...
Customs transaction value rejection requires communicated reasonable doubt, while written reassessment acceptance preserves challenges to enhanced val...
Challenge-mechanism compliance clarifications permitted, while unilateral revised resolution plans may be refused under creditors' commercial discreti...
Section 112(3) confines the prescribed limitation period to filing an appeal before the Tribunal and does not impose a separate six-month deadline on the Commissioner to review the first appellate order. A departmental appeal filed within the applicable extended filing period therefore remains maintainable even where the Commissioner's review occurred after six months. The maintainability objection was rejected, and the appeal was admitted for adjudication on merits.
Section 112(3) confines the prescribed limitation period to filing an appeal before the Tribunal and does not impose a separate six-month deadline on the Commissioner to review the first appellate order. A departmental appeal filed within the applicable extended filing period therefore remains maintainable even where the Commissioner's review occurred after six months. The maintainability objection was rejected, and the appeal was admitted for adjudication on merits.
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TaxTMI 
TaxTMI 
of 4916 
